ML17347B555

personnel;

including

one contractor,

indicated that the contract

personnel

were

being

eliminated

and

would

no

longer

be

used

in

routine circumstances.

As noted in 2.e.,

a program instituted

by the licensee

to minimize

parts

availability

problems

appears

to

be

effective,

though

additional efforts will be required to achieve

an acceptable

status.

I

Technical

Support

The elements

of technical

support which contained 'apparent

weaknesses

that contributed to the poor rating were implementation of corporate/

internal

communication,

engineering

support,

quality control

and

(personnel)

safety;

and the

absence

of any program for or

use

of

probabi listic ri sk

assessment

(PRA) .

In the current

inspection,

weaknesses

for these

elements

were

re-examined.

In addition,

the

inspectors

further

examined

the integration of regulatory

documents

into the maintenance

process

and the licensee's

preventive/predictive

maintenance

as

elements

of

technical

support.

The

inspectors

findings for each

element

are described

below.

( 1)

Internal/Corporate

Communication

The MTI'identified two weaknesses, for this element.

(a)

The'ack

of management

tours/walkdowns

of the plant for

'irect

communication

through

observation

of maintenance-

related activities

and

conditions

and

interaction

with

plant personnel.

(b)

The

apparently

poor

communication

between

Corporate

engineering

and

the

plant

on

technical

. problems

as

evidenced

by

poor

communications

a rust

and

. debris

inspection

conducted

in

response

to

NRC Generic Letter 88-14

With regard

to (a),

in the current

inspection

the inspectors

found that various walkdowns were being performed

by managerial

and

systems

engineering

personnel.

The

NRC inspectors

examined

procedure

O-ADM-008, which specifies

the performance

of manager

and

supervisor

walkdowns

and

the activities

to

be

observed.

Walkdown deficiency tracking lists (entitled

"Management

walkdowns

Trending .Data)

covering

the

period

of August 18-October

27,

1989,

were

verified

by

the

inspectors.

System

Engineers

walkdown records

were verified as

indicated

in 2.a.

above.

It

appeared

to

the

NRC

inspectors

that

the

walkdowns

were

contributing to

a better

understanding

of,

and to improvements

in plant conditions.

The

NRC

inspectors

further

examined

the

apparently

poor

communications

between

Corporate

engineering

and

the

plant

referred

to in (b)

by reviewing both subsequent

communications

on

the

rust

and

debris

inspections

and

by, reviewing

Corporate/plant

communications

in

addressing

other

similar

technical

issues

(as

described

in

(7)

below).

The

NRC

inspectors

found that the original communication

problem example

apparently

had

been

corrected

and that, for the

other

issues

checked,

there

were satisfactory

communications.

An example of

erroneous

internal

communications

associated

with

design

verification testing of GL88-14 valves

was

found,

however,

as

described

in (7) below.

(2)

Engineering

Support

The significant weakness'es

perceived

by the MTI for engineering

support

included

inadequate

specifications

o'f post modification

testing details,

inadequate

application

of

system

engineering

concepts

and evidence that recurring equipment deficiencies

were

not being corrected.

(a)

Post Modification Testing

In response

to the

concern

expressed

in the MTI, licensee

personnel

indicated that

the

MTI team

had

reviewed their

less

complex Design Equivalent Engineering

Packages

(DEEPs)

rather

than their more

complex

Engineering

Packages

(EPs)

and that,

since

the

DEEPs

were

non-complex,

specification

of their

ordinary

post

maintenance

testing

had

been

sufficient to demonstrate

adequate

function and operability.

However,

they revised

procedure

gI-3.7,

Design

Equivalent

Changes,

to clarify the testing

requirements.

The

NRC

'inspectors

reviewed gI-3.7 (7/89), three

examples

of post

modification testing

selected

and provided

by the licensee

and

two recent

examples

selected

by the

NRC inspectors

themselves

(Plant

Change/Modifications89-068

for

containment

sump solenoid valve replacement

and

89-373 for

modification to

Residual

Heat

Removal

valves to -preclude

hydraulic

lock).

Based

on their

review

the

inspectors

found no deficiencies

in the post modification testing.

(b)

System Engineering

The

MTI concluded that system engineering

concepts

had

not'een

adequately

implemented

as it was

found that

the

licensee's

system

engineer s

generally

had

not

become

adequately

fami liar with their

systems,

were

working

on

problem

components

rather

than

systems,

had

not received

adequate

training,

were

insufficient

in

number,'ad

poorly-defined responsibilities,

were not readily provided

with system work order

and failure information,

and about

,half of them were contractors.

In the current inspection

the

NRC inspectors

reexamined

the

licensee's

system

engineering

program

implementation

through interviews with the responsible

supervisor

and five

system

engineers,

review of examples

of records

of their

system

walkdowns

(September

1989 walkdowns for 480V Motor

Control, Center,

Reactor

Coolant

and Auxiliary Feedwater

Systems

and August

1989

walkdowns for Auxiliary Feedwater

and

Reactor

Coolant

Systems),

review of

procedures

for

their duties

and responsibilities

and for performance

of

root

cause

analyses

(0-ADM-501

and

509

and

Technical

Department

Instruction

TDI-SE-004),

review of root cause

analyses

(RCA

89-015

and

ERT

89-013),

and

Limiting

Condition for Operation

(LCO)

hours

data

on

Main

Steam

Isolation

Valves

(MSIVs) used'y

a

system

engineer

in

assessing

MSIV performance.

Some

of the

NRC inspectors

positive findings were

as follows.

Procedures

defining

system

engineer

responsibilities

" had

been

implemented.

The

number of system

engineers

had

been

increased

to

about

29

and all but

3 were

now licensee

employees

rather than contractors.

This was adequate

to resolve

the

,MTI

concern

regarding

insufficient

system

engineers

and having too many contractors.

The licensee

had training plans set

up for the system

engineers

and

a number were currently in training.

The

systems

engineers

were actively participating in

system

problems

through

system walkdowns,

involvement

in root

cause

analyses,

arid receipt

and

review of

failure information.

Negative aspects

of the current

systems

engineering

program

implementation

noted

by the

NRC inspectors

included:

< The

relatively

short

time

the

program

had

been

operating.

The limited experience

and training of many of the

systems

engineers.

Some

had received

no turnover from the, previous

system

engineers.

Malkdowns had only been in affect for

a few months

on

many of the systems.

In reviewing system

and design engineering

involvement in a

hydraulic

lock failure of

Residual

Heat .Removal

(RHR)

System valve MOV-4-751 (documented

in Licensee

Event Report

50-251/89-04),

the

NRC inspectors

discovered

errors

on the

(c)

involved drawings,

Operating

Diagrams

5610-TE-4501

Sheet

1

and

-4510

Sheet

2.

The

4501

drawing depicted

the Unit 4

RHR hot leg suction

coming from the

Loop Chot leg whereas

it actually

comes

from

Loop

A.

The

4510

drawing

gave

incorrect flow directions

and

drawing references

from the

line

containing

valve

MOV-4-751.

These

drawings

are

utilized by Operations

personnel

and

they,had

failed to

identify or obtain correction of drawings.

The licensee's

explanation

was that Operations

personnel

were

so familiar

with the actual

locations of the involved components that

they

probably

never

referred

to

the

subject

drawing

locations.

The

drawing

errors

were

corrected

before

completion of the current inspection

and the plant manager

agreed

to perform

a further review for identification and

correction

of

any

similar

drawing

discrepancies.

The

drawing

discrepancies

identified

by

the

NRC inspectors

appear

to

be

a

violation

of

10 CFR 50,

Appendix B,

'Criterion

V

requirements

to

assure

that

activities

affecting

quality

shall

be

prescribed

by .drawings.

(Violation 250,'51/89-48-01,

Drawing Discrepancies).

Failure to Correct Recurring

Equipment Deficiencies

The

NRC inspectors

determined

that the licensee

has taken

actions

to assure

recurring

equipment

deficiencies

are

properly corrected.

Primary

among

these

actions

is their

now implemented

system

engineering

program referred to in

(b)

above.

Also

the

licensee's

predictive/preventive

maintenance

program

is

utilizing reliability

centered

maintenance

concepts

to

aid

in

addressing

recurring

problems.

The licensee

was already

aware of many of their

recurring

problems

and

had

instituted modifications

to

correct

them.

Examples

examined

by

the

NRC

inspectors

included

RHR

Pump

seal

modifications to prevent

excessive

leakage

and installation of Intake Cooling Water chemical

injection

to

preclude

degradation

of

Component

Cooling

Water

Heat Exchangers.

The

NRC inspectors

verified that the licensee

had

a plan,

including

a schedule,

to generally

upgrade plant condition

and

eliminate

recurring

equipment

deficiencies.

This

upgrading

plan

was

documented

to

the

Maintenance

Superintendent

in

a

memorandum

from the

Plant

Manager

entitled

"Plant

Material

Upgrade

Program

1990"

dated

October

31,

1989.

Further,

of three

recurring

problems

10

referred

to in the

MTI, two appear

to have

been corrected

and the third largely corrected with final correction to be

complete

by the end of 1990.

Acknowledgement of Risk Significance in the Maintenance

Process

In the

MTI

an

element

of maintenance

was evaluated

that

was

entitled

"Inspect

the

Role of Probabilistic

Risk Assessment"

(PRA) in the

maintenance

process.

It was

intended

that

the

licensee's

use of

a

PRA in planning,

scheduling,

prioritizing

and performing maintenance

work be assessed

as

an element which

the

NRC considered

important to the maintenance

process.

The

MTI found that the licensee

did not use

PRA information or even

have

a

PRA

for

their

plant.

Subsequently,

the

NRC

has

acknowledged that application of other risk assessment

processes

utilized by the licensee

should

be considered

in judging their

maintenance.

In

the

current

inspection

the

NRC

inspectors

briefly examined

the overall status of Turkey Points

use of risk

assessment

in their maintenance.

They found that the licensee

has

committed to

have

a

PRA completed

and in use

by June

30,

1991.

The licensee

has

begun

using reliability assessments

that

give priority to planned

maintenance

and modifications

intended

to reduce

unplanned

days off line.

Additionally,

LCO hours are

considered.

Reliability Centered

Maintenance is beginning to be

employed.

Guidance

procedures

have

been

developed

for risk

analysis

in the design modification process.

The

inspectors

concluded

the

licensee

had

- undertaken

the

initial implementation

of

a program that would wholly address

NRC concerns

regarding their application of risk assessments

to

maintenance.

Quality Control

The examination of Quality Control

(QC) during the

MTI revealed

weaknesses

associated

with the

lack of

manpower

(i.e.,

insufficient

QC inspectors

and attendant

excessive

overtime-

estimated

at

50/,

on the

average)

and apparent

inadequate

peer

inspection

by the

maintenance

journeymen.

The insufficient

manpower

was exhibited

by craft complaints of excessive

delays

for inspection

of

QC hold points together with the fact that

available

QC inspectors

were five or- less

for all activities

other

than receipt

inspection.

The inadequate

peer

inspection

was evidenced

through observation

of less than adequate

control

of cleanliness

by the craft. during work which required opening

of the Reactor Coolant System.

was

reexamined

during

this

inspection

to

provide

an

opportunity

to

review

corrective

actions

and

a

current

assessment

of this

element.

The

inspectors

held di scussions

.

11

with cognizant

QC and craft personnel

and examined

documentation

as follows:,

IMA Commitments

(Commitments 'based

on recommendations

of

an

Independent

Management

Appraisal

that

was

conducted

between

December

1987

and March 1988)

140 - Emphasis

on QA/QC

143

Increase

of QC inspections/surveillance

Pareto

(root

cause

analysis

method)

data

package

on

field. performance

monitoring

Pareto

analysis

of recurring problems identified during

inspections/survei llances (i .e.,

root" cause

of

high

QC.

reject rates)

trend

analysis

report

from inspections/surveillances

during week of September

25 to October 1,

1989

QC trend data for month of September,

1989

trend

analysis

report

from inspections/surveillances

conducted

in the third quarter of 1989

Blanket

Purchase

Order

B89950

9000

for additional

inspectors

during outage

During examination of the above the inspectors

noted apparently

adequate

corrective actions

as follows:

Reduction of

QC overtime

from about

50% during the MTI to

37% for January

1989

and to

7% for

September

1989).

The

reduction

of

QC overtime

has

been. accomplished

through

allocation/hiring additional staff (from allocation of 6,

with

5 positions filled during

the

MTI to

a

present

allocation

of ll with

8 positions filled and

active

solicitation for

3 additional

permanent

inspectors

and

a

blanket

Purchase

Order for

3 additional

inspectors

during

.outage)

together

with more effective

use of personnel

to

increase field performance

(inspections

and surveillances)

Increased

field

inspections

and

surveillances.'or

example, total

QC activities increased

from 376 during last

quarter

of

1988 to

544

during first quarter

of

1989.

During this

same

period

surveillances

increased

by

26%

without decreasing

the necessary

inspections.

The increase

in surveillances

was partly due to increased

manning levels

but was primarily a directed

increase

in response

to the

12

analysis

of the field monitoring functions.

Discussions

.

with craft

personnel

indicated

there

were

no

longer

significant job delays resulting

from

a lack of timely (}C

inspections.

Adequate

peer

inspections.

Indirect evidence

of improved

peer

inspections

was obtained through

a detailed

review of

the licensee's

trend analysis of gC findings for the third

quarter

1989.

Indications are that these

gC activities are

conducted

very

thoroughly

and

lack

of

adequate

peer

inspection

was not evident for the discrepancies

identified

during

gC inspection activities.

The

inspectors

concluded

that

corrective

actions

have

been

sufficient to resolve

MTI concerns

regarding

gC at Turkey Point

Nuclear

Plant

(TPN).

Emphasis

on

gA/gC

has

been

further

fostered

by plant management

in response

to IMA commitments

140

and

143.

(5)

Safety

Review of Maintenance Activities (Personnel

Safety)

The MTI judged the licensee's

implementing actions to insure the

safety of maintenance

personnel

to be poor.

Their judgement

was

based

on the following perceived

weaknesses:

'I

(a)

Inadequate

attention

to fire hazards

as

observed

by team

members

in the welding

shop

(b)

Poor

safety practices

with regard

to the

use of air tools

and safety belts

as

observed

in the team's

tours of 'the

plant

(c)

Above aver'age

Industrial Safety Lost Time Accident Rate

(d)

The

licensee

did not determine their Lost Time Accident

Rate for Personnel

Involved in Maintenance

for comparison

with industry averages.

The

NRC inspectors

toured

the plant

and

observed

maintenance

activities in the current inspection

on at least, five occasions.

No evidence

of poor safety practices like those referred to in

(a)

and (b) were observed.

These

tours

included

two visits to

weld shops.

The inspectors

reviewed the

TPN Industrial Safety

Lost

Time Accident

Rate

and

found that

the

running

average

showed

no lost time accidents

since April 1988.

With regard to

TPN's failure to determine their "Lost Time Accident

Rate for

Personnel

Involved in Maintenance,"

as referred to in (d), the

licensee

responded

that thi s data

was

no longer being

used

by

the industry

as of the

end of 1988.

The licensee

had

several

13

personnel

safety

performance

indicators

they

were

tracking

closely - e.g.,

lost

time injuries

were

being

tracked

by

department.

Licensee

personnel

reported

that

beginning April

1989

root

cause

of injuries

was

being

analyzed

by the site

safety

organization

using

a

Corporate

accident

investigation

process.

The

NRC

inspectors

verified

the

manual

for this

process.

The inspector

s also

found that specific

supervisors

has

been

made individually accountable

for important aspects

of

personnel

safety.

The

NRC inspectors

did

see

a

few minor infractions of safety

rules while on their tours,

such

as

an instance

of not wearing

a

hard hat where requi red (the conditions in the area did not make

this

a significant hazard)."

However,

the inspectors

generally

concluded that their previous concerns with regard to personnel

safety practices

appeared

to have

been resolved.

Preventive/Predictive

Maintenance

An

examination

of preventive/predictive

maintenance

was

not

completed

in sufficient depth during the

MTI for inclusion of

this

function

in

the 'xamination

of

engineering

support.

Therefore,

preventive/predictive

maintenance

was

thoroughly

examined

during

this

inspection

to

provide

separate

and

additional

data

in reassessing

this element.

Preventive/predictive

maintenance

at

TPN is the responsibility

of

the

Planned

Maintenance

Group

(PMG).

PMG historically

provided

predictiVe

maintenance

(vibration

monitoring,

oil

analysis

and

thermography)

on

most

plant equipment.

PMG

now

also

supplies

maintenance

support

in

areas

of root

cause

analysis

to prevent failure recurrence

on major plant equipment;

i.e.,

reduction

of plant

LCO

hours,

together

with

use

of

Reliability Centered

Maintenance

(RCM) techniques

to identify

preventive maintenance

requirements

on selected

plant equipment;

i.e.,

reduce

unplanned

days off line.

The

inspectors

examined

procedures,

had

discussions

with

cognizant

licensee

personnel,

and

exami'ned

documentation

to

assess

whether predictive/preventive

maintenance

appeared

to be

adequately

controlled

and

implemented.

Procedures

and

documentation

examined were's

follows:

Procedures

0"ADM-705

0-ADM"706

Planned

Maintenance

Program

Predictive Maintenance

Program

14

0-ADM-710

Processing,

Schedul ing,

and

Upgrading

Preventive

Maintenance

Documents

0-ADM-711

0-ADM-712

0-ADN-716

Vibration monitoring

Lubricating Oil Sample

Processing

Infrared Thermography

Documentation

Logic Flowchart

on Root Cause

Analyses

by

PMG

Logic Flowchart

on Reliability Centered

Maintenance

Process

Pareto

analyses

package

to

improve

equipment

reliability thru

RCM Techniques

(Copes-Vulcan valves)

Quality Investigation

Story (QIS) data

package

on

3B

Steam

Generator

Feedwater

Pump

Operational

Problems

(combination

of

vibration/lubrication

problems

requiring

complex

analyses

and

PC/M modifications to

resolve)

QIS data

on

attempt

to

increase

Mean

Time

Between

Failure

( single

point failures)

by identification/

criticality ranking of TPH critical components

Examples

of

Thermography

Interdictions

to correct

discrepant

equipment conditions

(1)

excessive

thermal

aging of 13 reactor protection

relays (Units

3

8 4)

(2)

thermal

anomalies

on

the

U3

main

power

transformer

due to failed cooling oil circulating

pump.

(3)

ineffective cooling coil of normal

containment

coolers

in Unit 4.

Examples

of

vibration

analyses

which

allowed

corrective actions to prevent catastrophic

failures

(1)

damage

to

impeller,

seal

end

bearings

on

Condensate'ump

2A

(2)

defective top motor bearing

on Condensate

Pump

3A

15

(3)

damaged

roller

thrust

bearing

on

Auxiliary

Feedwater

Pump

A turbine

(4)

defective

inboard

bearing

on

Component

Cooling

Mater

Pump

3A

After examination of the above the inspectors

concluded that the

items

reviewed

indicated

a

strong

and

well

implemented

predictive/preventive

maintenance

program.

However,

the

inspectors

expressed

some

concerns

regarding

the

need

for

a

formal requirement

in 0-AON-711 that the

PNG vibration analysis

program properly inform inservice testing

program

personnel

on

evidence

of vibration in the alert

ranges

on- ASME components.

The inspectors

also

noted

need

for further details

regarding

specifics

on

oil

sample

analyses

to

be

conducted

under

0-ADM-712.

Cognizant

licensee

personnel

agreed

and

provided

acceptable

revisions

of

0-ADM-711

and

0-ADM-712 for

the

inspectors'eview

prior to the

end of this inspection.

(7)

Integrate

Regulatory

Requirements

During

an

MTI examination related to the integration of changes

to regulatory documents

into the maintenance

program,

there

was

a

concern

identified

regarding

inadequate

plant/corporate

communication

associated

with Generic Letter 88-14

on instrument

air systems.

The

inspectors

examined

procedures,

held

discussions

with

cognizant

licensee

personnel,

and

examined

documentation

to

assess

whether

changes

to regulatory

documents

appeared

to

be

properly integrated

into the maintenance

program.

Licensee

Res

onses

to IE Bulletins

Response

No.

Issued

Comments

88-04

6/16/89

Potential

safety-related

pump

Loss

due

to

miniflow design conditions.

The licensee's

response

was completed after

receipt of pertinent, vendor design data

and

covers the question of hydraulic instability

(need

for adequate

miniflow capacity)

and

potential

for deadheading

for the

Safety

Injection,

RHR, Containment

Spray, Auxiliary

Feedwater

(AFM)

and

Boric

Acid Transfer

(BATF)

pumps'iniflow

capacity

was

adequate

for all,pumps

and,

under worst case

conditions,

only the

BATF pumps

have

a

16

Licensee

Res

onses

to IE Bulletins (cont'd)

Response

No.

Issued

Comments

potential for deadheading.

This possibility

has

been

precluded

through

corrections

to

operating

procedures.

88-08

5/4/89

Thermal

stresses

in piping connected

to the

Reactor

Coolant

System

(RCS)

which

could

lead to unisolable leaks..

The licensee

identified potential locations

and committed to additional

NDE examinations

for welds in portions of the charging

pump

.

to pressurizer

auxiliary

spray

line,

and

charging

pump for "C" hotleg.

88-11

5/31/89

Pressurizer

Surge

Line Thermal Stratifica-

tion

which

could

damage

surge

line

integrity.

The

licensee's

response

noted

their

participation

in

the

Westinghouse

owners

group's

program

to

perform

a

generic

evaluation

of

this

issue

and

present

justification for continued

operation until

completion of all plant specific actions

by

January

1991.

89-1

.

6/19/89

Failure

of

Westinghouse

steam

generator

mechanical

plugs

due to potential

inadequate

heat treatment.

The

licensee's

response

verifies that

six

plugs

from heat

4523 are installed

in the

Unit 3

"C"

steam

generator

and

two plugs

from heat

4523 are installed in the Unit 4

"A"

steam

generator.

The

plugs will be

replaced

during the next refueling outage.

Licensee

Res

onses

to

NRC Generic Letters

Response

Issued

Item

3/10/89

Instrument

Air

Supply

Systems

Probl ems

Affecting Safety-Related

Equipment

17

Licensee

Res

onses

to

NRC Generic Letters (cont'd)

No.

Response

Issued

Item

A weakness

regarding

lack of communication

between

plant

and

corporate

personnel

associated

with

was

identified

during the MTI.

Therefore,

licensee

actions

in

response

to

GLSS-14

were

examined

in

considerable

additional detail'uring this

inspection.

The results

are reported

below:

The

inspectors

did not identify any other

examples

of apparent

lack of communication

between plant and corporate

personnel

during

this

inspection

except

as

noted

below

relative to work order DI-3304.

Additional

documentation

associated

with

examined

during

this

inspection

included

plant

procedures

and

drawings,

plant

work

orders,

test

results,

audit

reports

and correspondence.

During the examination,

the inspectors

noted

the following:

Another

example

apparent

lack

of

internal

communication in that internal

correspondence

regarding

completion of

work

associated

with

DI-3304

was

inaccurate

in that the required

design

basis

verification

testing

was

not

completed for all valves listed

on the

work order.

Flow Control Valves (FCVs) and Pressure

Control

Valves

(PCVs)

not tested

are

listed below:

FCV"""113A

FCV""-113B

FCV-"-114B

PCV-"-605

PCV-*-455A

PCV"*"455B

Boric Acid

to Blender

Borated water

to Change

Pump

Diluted flow

to VCT

RHR Ht. Exchanger

Bypass

PZR spray

FO

FC

18

Licensee

Res

onses

to

NRC Generic Letters (cont'd)

Response

Issued

Item

Cognizant

licensee

personnel

informed

the inspectors that licensee identifica-

tion of the lack of testing

noted

above

would

have

occurred

during

their

independent

gA verification of actions

in

response

to

NRC commitments,

which

is required prior to the submittal of a

final response

on GL88-14 to

NRC.

valves

without

filter

regulators

and filter-regulators not in

PM program.

The

inspectors

noted that

some

valves

(containment

purge valves

and main feed

check

valves)

were

not

protected

by

individual

filter

regulators.

Cognizant

licensee

personnel

responded

that final evaluation

of air quality

limits was not complete,

but that tests

completed

together

with

preliminary

.vendor information did not indicate

any

immediate operability problems.

The inspectors

were

informed that

some

filter regulators

were

not presently

included

in

. the

PM

program

pending

evaluation

of air quality tests

and

receipt

of

vendor

information

to

establish

the

most

efficient

PM

frequency.

Lack of tests

to validate Unit 4 Main

Steam

Isolation

Valve

(MSIV)

accumulator

size at 85 psig minimum

During review of the design

bases

for

Unit 4

MSIV

accumulators,

the

inspectors

noted

differences

between

valves

stated

in

PC/M

No.88-245 for

Unit 4

MSIVs

(80 scfh

at

85

psig)

versus

those

stated

on

PC/M No.85-135

for Unit 3

MSIVs (nitrogen

backup

of

100 scfh at

100 psig).

The inspectors

requested

additional

verification

of

Unit 4 sizing data

since Plant

Change

19

Licensee

Res

onses

to

NRC Generic Letters (cont'd)

No.

Response

Issued

Item

GL89-4

10/3/89

Modification (PC/M) No.88-245 inferred

that

80 scfh

and

85 psig

were

design

limits.

The

inspectors'eview

of

calculation MIZ-165-02 revealed that

an

accumulator

design

pressure

of 100 psig

was

used

in the design.

However,

the

calculation anticipates

a minimum of 85

psig to assure

MSIV closure within'ive

seconds.

The inspectors'further

noted

that this anticipated

minimum pressure

was

not verified during completion of

preoperational

testing

(procedure

0800.213)

since

those

tests

were

conducted

at

normal

system

pressure

(100

psig)

rather

than

85

psig

~

Cognizant

licensee

personnel

provided

correspondence

verifying

FPL

and

Bechtel

Power

Corporation

(BPC)

agreement

that calculation

MIZ-169-02

will be revised

and reviewed to assure

that

any additional

necessary

testing

is completed.

Guidance

of Developing Acceptable Inservice

Testing.

GL89-4

provided

the

latest

guidance

on

NRC positions

associated

with

relief requests

from

ASME Section

XI

Code

Requirements

on the inservice

testing

(IST)

of

pumps

and

valves.

The

licensee's

response

notes that conformance

with GL89-4

will require revision of nearly all present

TPN IST surveillance

procedures.

Therefore,

full conformance will not be obtained until

tests

performed after July 1,

1990.

Safety

Valve Testing

and Surveillance.

expands

the

scope

of

licensee

programs

for

MOV testing

and

surveillance

which

was originally required

by

IEB 85-03

to

now

include

all

safety-related

and

position-changeable

MOVs.

the

inspectors

examined details associated

with MOVs to

20

.

Item

Licensee

Res

onses to

NRC Generic Letters (cont'd)

Response

No.

Issued

assess

whether

management

had

expanded its

concern

to addressing

MOV problems.

The

FPL response

to GL89-10 was not required

prior

to this

inspection.

However,

the

inspectors

examined

the

latest

informal

draft together with supporting documentation.

The inspectors

found that the

licensee

had

anticipated

and

completed

several

actions

associated

with

prior.

to

its

issuance.

Cognizant

licensee

personnel

noted

that

considerable

costs

have

been

associated

with

work

completed

to

date.

Further, that strong

FPL management

support

has

been

.provided

in

completing

those

activities.

The

expanded

MOV

testing

program at

TPN includes:

1)

development

of a design basis including

the manufactured

stem thrust value for

each valve

2)

verification of switch settings

3)

administrative

control

of

switch

setting

by an engineering

drawing

4)

performance

of

delta-P

testing

for

valves which will not place the unit in

an

LCO or unreviewed

safety

question

concern

5)

EPRI

and

MOV user group recommendations,

data

bases

and

trending

information

will be incorporated

as applicable.

The

inspectors

noted

.that

had

required

revision

or generation

of sixteen

procedures,

expansion

of

the

IEB 85-03

program

by

nearly

400

percent,

and

considerable

additional

costs;

i.e.,

56

man-rem

and.

96

man-hours

for each first

round test

per

MOV,

7

personnel

per test

(technicians,

engineers,

'HP), etc.

The

21

Licensee

Res

onses

to

NRC Generic Letters (cont'd)

Response

Issued

Item

inspectors

concluded that management

concern

and support, for

MOV testing

was sufficient

to resolve

any

NRC concern.

The

inspectors

further

concluded

that

licensee

actions associated

with integration

of regulatory documents

were above average.

d.

Work Control

In the

MTI, three

elements

of Work Control contributed to

a poor

rating.

These

were

implementation

of work order

control,

job

planning

and ma.intenance

procedures.

In the current inspection

these

were

reexamined

to determine

whether

the

licensee

had

undertaken'ctions

to obtain

improvements

and whether the actions

were effective.

The

inspectors

reviewed

licensee

actions

relative

to work order

control

and job planning together

and examined

maintenance

procedures

as

a separate

topic.

Work scheduling,

which was not rated in the MTI

was examined together with work control

and job planning.

C

Also

examined

separately

were

the work controls

on maintenance

in

'rogress

and

post

maintenance

testing.

Neither of these

had

been

rated in the MTI.

The inspectors

conducted

thei-r examination of these

elements

through

interviews with planners,

scheduling

and craft personnel;

through

observation

of the

development/preparation

of

a Plant

Work Order

(PWO)

and of

use

of the

involved data

bases;

through

review of

completed

PWOs

and

Plan of the

Day (PODs);

and through attending

a

POD morning meeting.

Findings are described

below:

(1)

Work Order Control, Job Planning

and Scheduling

The significant

concerns/weaknesses

described

in MTI findings

and the

NRC inspectors

current

inspection

findings relative to

each

are

as follows:

ff

accessing

the job planning

system

data

bases

to identify

whether

a job was

rework,

was

becoming

a trend or if the

job

had

been

performed

previously

under

a different

classification.

The

NRC inspectors

perceived that this was

at

least

partially

due

to

inadequate

or

insufficient

.training.

22

Current ins ection findin

s

The licensee

analyzed

these

concerns

and responded

to them with actions which included

development

of

a checklist

to

aid

in

planning

PWOs;

modification of the planning

system

to permit identifica-

tion

of

multiple

component

failures

under

one

PWO

(previously only one

was identified to the

PWO

and

thus

other s corrected

could not

be readily called-up

from the

computerized

work history

system);

modification

of the

system to permit

a search for "root-cause

component"

in the

data

base;

advising

planners

of their responsibilities

to

identify

rework

and

directing

them

to

submit

PWOs

identified as rework to the maintenance

engineers

for root

cause

analy'ses;

conducting additional

planner training and

developing

a

planner

training

course;

hiring additional

planners;

and issuing

a revised planning

system

manual for

reference.

From their review of these

licensee

a'ctions,

observations

of

planning

reviews

of

PWOs

and

from interviews,

the

inspectors

determined

that

the

licensee's

actions

had

resulted

in

improvement.

Some

minor

concerns

were

identified,

however.

First,

the

licensee

had lost several

of the

maintenance

engineers

who

performed

root cause

analyses. of recurring

equipment

failures.

(They

were

attempting

to

hire

replacements.)

Second,

the

equipment

history

records

entered

in the past

lack details

and

easy

accessibility

.

(The

inspectors

were

informed that

only

1988

and

1989

records

were readily accessible

in the data

base - though

entries

back

to

1986 could

be obtained,

access

now took

longer

and they were generally

not, checked.)

not

be

readily

ascertained,

making it difficult to

accurately

assess

the maintenance

backlog.

Current ins ection findin

s

Licensee

personnel

reported

that

a daily

summary

report

had

been

developed

which

provided

accurate

information

on

backlog

to

planning

supervisors.

Based

on

the inspectors

review of licensee

backlog

information

and

discussions

with

scheduling

personnel

the inspectors

found no further

cause for concern

regarding this matter.

N~ii

E

inaccurate

and the

causes

of these

discrepancies

were not

being recognized

or corrected.

In particular,

bottlenecks

caused

by

some

of the

smallest

organizations

were

not

acknowledged.

23

Current ins ection findin s - The inspectors

examined

the

1989 estimated

versus

actual

man-hours

for the Electrical

and

18C .Maintenance

Departments.

The estimated

hours

were

ll'nd .18%

low,

respectively.

They

judged

the

18%

difference to be excessive,

but not of great concern

as the

numbe'r

or trend of open

maintenance

PWOs did not appear

excessive.

The

inspectors

were

informed there- had

been

significant .improvements

in

estimates

between

1988

and

1989.

Craft

personnel

and

planners

interviewed

by

the

inspectors

attributed

the. improvement

to

improved

parts

availability,

improved

support,

and

(especially)

reduction of waiting time for clearances.

One craft person

also noted better

supervision

as

a reason.

The principal

negative

factor

indicated

was still parts availability

(though

greatly

improv'ed).

Other

negative

factors

mentioned

included

insufficient

supervisors,

increased

paperwork

and getting

clearances

lifted.

The

inspectors

found

that

PWO

forms

and

the

associated

procedure

(0-ADM-701) required

discrepancies

between

estimated

and

actual

man-hours

to be explained

when they differed by more

than

20% but that,

based

on their review of PWOs, this was

not

being

done.

This

appears

to

have

only

minor

'ignificance

as

a

safety

issue

but is certainly

not

in

agreement with,the plant manager's

expressed

intent which

is to have "verbatim compliance" with procedures.

(d)

~TI

i

i -"P0

"(GO)ii bh

licensee

to indicate

important daily work activities did

not provide

information

needed

to fully understand

the

schedule

priorities

and

the

problems

that

had

to

be

resolved= to accomplish

the schedule.

Current ins ection findin

s - The inspectors

attended

one

licensee

morning

meeting

in

which

the

POD

items

were

reviewed

by

management

personnel.

Also,

the

inspectors

examined

several

PODs during their inspection.

They found

the

POD greatly

improved.

It appeared

to communicate all

of the

more

important information

needed

for managers

and

supervisors

to

understand

the

status

of

plant

work

priorities

and

important

problems requiring attention

and

resolution.

Of particular significance

were

items

added,

such

as

a

three

day 'schedule

of

'maintenance

work,

procurement

status,

control

room

green

tag

(deficiency)

status-report

and contaminated floor space

status.

(e) ~li

i

-A

k

1

k

,.the

planning

procedure

(0-ADM-701)

contributed

to

a

planners

erroneous

closure of an instrument deficiency.

In

starting to plan correction of the deficiency the planner

went to observe

the

instrument.

He

examined

the

wrong

instrument

(whose identification

was missing)

and fai ling

to observe

any deficiency

he coded or closed out the

PWO as

"finished."

Had

he

cancelled

the

work order

as

being

invalid the originator of the

PWO would have

been contacted

to verify the

absence

of the deficiency

and the error in

checking

the

wrong

instrument

would likely

have

been

recognized.

This matter

was identified

as

part of

NRC

violation 250,251/88-32-02,

Procedural

Related Deficiencies.

In

a written response

to this violation included in a May

1989 letter

to the

NRC,

the

licensee

stated

that their

corrective

steps

included instructing planning supervisors

'hat

PWOs'ere

not to

be

closed

out if no

work

was

performed

but

were

to

be

processed

for cancellation

and

that 0-ADM-701 had

been revi sed to reflect this.

Cu'rrent ins ection findin s

Through

interviews

with

planning

personnel

and

review

of

O-ADM-701,

the

NRC

inspectors verified the stated corrective actions.

W

J

W

d

being completely

entered

in the computerized

work history

data

base,

though this

was

required

by procedure.

Data

entry technicians

without any related training

or

formal

guidance

were

determining

what

information

would

be

entered.'his

matter

was cited

as part of the violation

referred to in (e) above.

In the

same

response

referred to

in (e) the licensee

stated that their'orrective

action was

to revise the

PWO procedure

(0-ADM-701) to state

that the

relevant

Journeyman's

Work Report data would be entered

by

a designated

data technician.

Current ins ection findin s

The inspectors

found that the

procedure

revision

had

been

made

as

stated.

Planners

stated

that the data entry clerks

had

been

instructed

to

enter either the

complete

Journeyman

Work Report data or

the

relevant

data.

Also,

they

were

to

consult

with

planning

personnel if there

was

any question

of what to

enter.

A check of entries

in the computer data

base for a

sample

of about

10

1989

PWOs

found the data

entry clerks

were

entering

relevant

data

from the

Journeyman's

Work

Reports.

However,

the

inspectors

noted

another

concern.

Of 12 completed corrective maintenance

(trouble

and break-

down)

PWOs

reviewed,

cause

did

not

appear

adequately

addressed

on nine (e.g.,

on

WA 89102200738,

89103020073

and

891025090638).

Also,

in

one

instance

35

PWO steps

were

used

to

prescribe

the

work

to

be

performed

(on

WA

891025090638).

It appeared

to the

inspectors

that

such

extensive

prescription of work should

have

been

specified

through

an approved

procedure.

The

PWO procedure

(0-ADM-701) requires

an entry of a best

estimate

of the

root

cause

of the

problem

found.

The

25

procedure

also

provides

examples

of cause

entries.

These

examples

did not appear

to

be actual

root causes

and the

inspectors

considered

that they represented

an

inadequacy

in the procedure.

The inspectors

found that the licensee's

work order control

and job planning

had been

improved significantly since the

MTI.

The

number of planners

had increased,

the planners

had additional

experience

with the system,

checklists

were

being

used

to

assure

correct

PWO data

entries,

further

improvements

had

been

made to the planning

systems,

parts

availability

and information

had

improved

and

communica-

tions

were better.

Also,

the

licensee

appeared

to have

taken

the

necessary

actions

to assure

proper

scheduling.

Additional

improvements

were

seen

as

being

needed

in

-identifying

and

recording

(on

PWOs)

the

root

cause

of

equipment failures whose significance level

was insufficient

to trigger

a

formal

analysis.

The work order

procedure

(0-ADM-701)

gave

inadequate

guidance

on

root

cause

identification.

The loss of several

maintenance

engineers

was also of concern.

(2)

Maintenance

in Progress

Several

examples of maintenance

in-progress

were observed

by the

inspectors

(e.g.

Unit

3

Charging

Pump

C fluid drive repair,

Unit 4

intake

Cooling

Water

Pump

C

inspection

and

stud

replacement

for

same

pump).

The maintenance

observed

appeared

to

be properly performed

in accordance

with the

PWO specified

requirements.

Work appeared

well organized,

properly controlled

and calibrated

tools were

employed (e.g.,

dial indicators for

Charging

pump

alignment),

and cleanliness

was maintained.

No

matters of concern

were noted.

(3)

Post Maintenance

Testing

The inspectors

examined

the licensee's

procedural

requirements

for post maintenance

testing

and the records of post maintenance

tests

performed

on

12

PWO examples

(those

referred to in (1)

above).

The inspectors

found that the

programmatic

procedure,

AP-0190.28

was thorough

and technically adequate

but that it was

somewhat

complex to use

and could be improved by rewrite to the

Procedure

Upgrade

Program style.

Each of the

PWOs

reviewed

by

the

inspectors

was

found to

have

performed

the

proper

post

maintenance

tests.

(4)

Maintenance

Procedures

Weaknesses

were

identified

during

the

MTI associated

with

procedures.

These

included

inadequate

procedures (for example,

O-PMM-022.3 which apparently resulted

from an inadequate

review/

26

validation process),

and

a lack of procedures (for example,

on

motor maintenance,

testing

molded-case

circuit breakers

and

sampl ing plant

breathing

air ),

and

a

lack of conformance

to

procedures

(for example,

0-ADM-701

on canceling

[coding out]

work orders,

required receipt

inspections

for ASME code parts,

and maintenance

of QA records

fQP 13. 1. 17..1

and O-HPA-003]).

Violations associated

with the

above

included 250,251/88-32-02

through

04.

The licensee's

response

to the

MTI violations was transmitted to

Region II nn May 4,

1989.

The inspectors

completed verification

of actions

reported

in the licensee's

response

together with

review of actions to correct other

weaknesses

identified in the

MTI report.

Regarding

the testing/validation

process,

enhanced

controls

pertaining to actual-use

validation for new procedures

were

incorporated

in the latest revision of 0-ADM-100.

Each

new

maintenance

procedure

must

be clearly marked

to indicate

"

that it has

not

been first-use validated

and

an attached

validation feedback

form (attachment

7 of ADM-100) must

be

completed

by

the

craft

performing first

use

of the

procedure.

The form, provides for comments relative to any

problems

as well as

suggested

solutions.

Improved

checklists

for

new

and

revised

procedures

to

ensure

adequate

procedure

evaluation

by originators

ahd

technical

reviewers

are

now

included

in

0-ADM-100

(attachments

3,

4 and 5).

Training

has

been

provided to procedure writers

on the

use

of these- checklists

as well

as

general

principals of good

procedure writing.

A

new

departmental

instruction

(TDI-PUP-001)

has

been

issued

which requires

a review of plant changes

by both an

operations

and

a maintenance

procedures writer.

Maintenance

management

has

encouraged

craftsmen

to provide

feedback

on procedure

problems.

0

Procedure

0-PMM-022 '

Deficiencies

in

O-PMM-022.3

were

the first part

of

violation 250,251/88-32-02.-

The procedure

was

revised to

delete

the

requirements

for

chromate

water

and

major

modifications.

Also,

the

licensee

identified

the

root

cause

of the earlier deficiency

as failure to ensure that

plant

changes

and

modifications

(AP-0190. 15)

were

also

reviewed

and

coordinated

with the

procedures

they might

27

affect.

Figure J of AP-0190. 15'(System

Acceptance

Turnover

Sheet)

was

revised

to

ensure

that all

procedures

not

required

for acceptance/turnover

but

requi ring revisions

due to the modifications involved also

be listed.

The

inspectors

concurred

with the

licensee

corrective

actions

and this part of violation

250,251/82-32-02

is

'onsidered

closed.

Testing molded-case circuit breakers

Maintenance

instruction

MI-E-023. 1

has

been

developed

for

periodic

inspection

and

testing

of

molded-case

circuit

breakers.

The licensee

plans to,test

10 of molded-case

circuit breakers

associated

with Appendix

R for protecting

safe-shutdown

capabilities

during

the

forthcoming

Unit 3

outage.

The

remaining

breakers

will

be

tested

in

subsequent

outages.

Similar testing will be conducted for

Unit 4 commencing

the next Unit 4

outage'ailure

to have procedures

to test breathing air quality

This

deficiency

was

the

second

part

of

violation

250,251/88-32-02.

The

licensee

issued

procedure

0-SMM-101. 1,

Grade

D Breathing Air Periodic

Testing,

and

completed initial sampling

and testing

of breathing

air

quality prior to this inspection.'The

inspectors

reviewed

the test results

and

noted that

Grade

D or better quality

breathing air was verified.

However,

the inspectors

noted

deficiencies with 0-SMM-101. 1 as issued.

The

licensee

initiated

actions

to

adequately

revise

0-SMM-101. 1

during

and

immediately

subsequent

to this

inspection.

This item is considered

closed.

Lack of procedural

requirements

for periodic retraining of

contract

HP personnel

This

deficiency

was

the

third

part

of

violation

250,251/88-32-02.

The licensee

issued

on March 8,

1989,

a

corporate

recommended

practice

(RP:

HP-001)

providing

guidelines for training and qualification of ANSI contract

technicians.

Procedure

O-ADM-360,

Health

Physics

'epartment

Personnel,

Training

and gualifications,'as

revised

to include contract

HP technician

training

and

certification requirements

(Sections

5.2 and 5.3).

The

inspectors

concurred

with the

licensee's

corrective

actions.

This item is considered

closed.

28

e

Lack of conformance with existing procedures

There

were

two

examples

of these

types

of deficiencies

associated

with violations.

The first deficiency

was

the

lack of conformance

with

0-AOM-701 in improperly

concealing

(coding-out)

a

work

order 'when

no work was done.

This item was the final part

of violation

250,251/88-32-02.

The

second

example

was

inadequate

receipt inspections

(RIRs R87-7772

and

RGG-3842)

for cleanliness

inspection

of ASME Code

Parts.

This was

considered

violation

250,251/88-32-03.

The

licensee's

corrective

actions

for

the

former

were

examined

and

determined

satisfactory

by the inspectors

as

described

in

. paragraph

2.d( 1)(f) above.

Regarding

the latter,

licensee

corrections

included

revision

of plant Quality Control

Department

Instruction

7. 1

and, technique

sheet

7. 1

to

referen'ce

ANSI 1145.2.2-1972

as

the

receipt

inspector's

cleanliness

standard

when

no specific criteria is available

.or indicated in the inspection

plan.

Additionally, the

use

of sampling

was prohibited

as

an inspection

technique

on

'SME

parts,

10 CFR 21 orders,

or

EQ parts.

The

inspectors

agreed

that these

corrective

actions

were

sufficient

to

, resolve

NRC

concern.

Violation

250,251/88-32-03

is considered

closed.

Failure to maintain temperature

and humidity daily records

for the Class

B storage

warehouse

as

QA records

This item was the first part of violation 250,251/88-32-04

and

demonstrated

a

lack of conformance

to corporate

QA

procedures

QP 13. 1 and

17. 1.

The

licensee

had

maintained

these

records

but,

due to

mi sinterpretation

of the corporate

QA manual,

they- were not

being

maintained

as'A

records.

Corrective

actions

included revision of the nuclear stores

QA records list to

include Class

B warehouse

temperature

and humidity records

as

QA records

and the transfer of all historical

records to

the

QA records

storage facility.

The inspectors verified the transfer of 1989 records to QA

storage

and

agreed that corrective actions

were sufficient

to

resolve

any

NRC

concern.

This

item is

considered

closed.

Failure to maintain qualification records for contract