ML18005A726
| ML18005A726 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/09/1988 |
| From: | Breslau B, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A723 | List: |
| References | |
| 50-400-88-34, NUDOCS 8812080118 | |
| Download: ML18005A726 (52) | |
See also: IR 05000400/1988034
Text
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'C
'NITED
STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W.
ATLANTA,GEORGIA 30323
Report No.: 50-400/88-34
Licensee:
Carolina
Power
and Light Company
P. 0.
Box 1551
Raleigh,
NC
27602,
Docket No.:
50-400
License No.:
Facility Name:
Shearon
Harris
Inspection
Conducted:
September
19-23 and October 3-7 1988
Inspectors:
B.
reslau,
earn
Leader
Team Members:
Date
gned
P.
Hopkins
P. Kellogg
T. McElhinney
P.
Moore
R. Schin
Approved by.
M. Shymlock',
hief
Operational
Programs
Section
Division of Reactor Safety
Date Signed
SUMMARY
Scope:
This was
a special
announced
Operational
Performance
Assessment
(OPA).
The 'OPA evaluated
the licensee's
current level of performance
in the area of
plant operations.
The inspection
included
an evaluation of the effectiveness
of various plant groups including Operations,
Maintenance,
Quality Assurance,
Engineering,
and Training in supporting
safe plant operations.
Plant
management
awareness
of, involvement in, and support of safe plant operation
was also evaluated.
The inspection
was divided into three major areas
including Operations,
Maintenance
Support of Operations,
and Management Controls.
Emphasis
was
placed
on numerous interviews of personnel
at all levels,
observation- of plant
activities and meetings,
extended control
room observations,
and plant and
system walkdowns.
The inspectors
also reviewed plant deviation reports
and
LERs for the current Systematic
Assessment
of Licensee
Performance
(SALP)
evaluation period,
and evaluated
the effectiveness
of the licensee's
root
cause identification; short term and programmatic corrective actions;
and
repetitive failure trending
and related corrective actions.
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Results:
The licensee's
Operations
department
exhibited
a high degree
of pro-
fessionalismm
and control.
The inspection effort was performed during
a three
week period in which the
licensee
was
completing its first refueling
outage
and continued
up through entry into mode
4.
This afforded the inspectors
an
opportunity to observe
the operations
department
performing activities that
required
a great deal of organization during
a period of potential
high stress.
Not once did the Operations
departmen't exhibit a lack of control .and
many times
the
calm demeanor
that
was
apparent
in the control
room belied the magnitude
and
scope of activities that were being performed in preparation for startup.
Contributing to this overall atmosphere
were
a number of areas that the inspec-
tors considered
to
be strengths.
Most notable
was the clearance
center that
was staffed full time by at least
two licen'sed operators.
The clearance
center
processed
all maintenance
requests
and generated
clearances
while maintaining
logs of inoperable
equipment,
caution
tags,
and
clearances.
The
clearance
center
also coordinated
much of the paperwork associated
with the many survei 1-
lances
required for startup.
This freed the operators
in the control
room to
concentrate
specifically on the performance
and scheduling of the surveillances.
In effect, the clearance
center provided
a buffer between
the operators
and the
plant personnel
needing to perform their jobs. It also
had
a positive effect
upon the maintenance
personnel
in that their needs,
requests,
and -requirements
were dealt with in an expeditious
manner.
Contributing to the functioning of
the clearance
center
were
what the inspectors
considered
very good communica-
tions.
(paragraph 2.b.)
Another noted. strength
was
the
use of shift information sheets
by each of the
operators
in the
control
room.
These
contributed
to the
highly organized
nature of the observed activities
and were very helpful in the
performance
of
complete
and accurate
shift turnovers,
which were also
judged
as
a strength.
(paragraph 2.a.(3))
Management
presence
in the
operations
area
and especially
the control
room
was apparent.
This
was
viewed
as
a strength of the operating
organization.
(paragraph
2. a. (1) )
Housekeeping
in the control
room areas,
reactor auxiliary building, contain-
ment,
and the turbine building was very good.
(paragraph 2.e.)
The licensee's
commitment
toward
pursuing
the "b'lack board"
concept
on the
panels
was also judged
a strength.
(paragraph 2.a.(4))
The
EOPs were found to be adequate
for the limited depth of these observations.
The inspectors
found
few areas
considered
as
weaknesses.
Of these,
the only
notable
one
was the area of caution tag audits.
A violation was cited in this
area;
the
weakness
was considered
to
be poor documentation
of resolution for
caution tags that
had
been
hung for more than three months.
(paragraph 2.b.)
The evaluation of Maintenance
Support of Operations
indicated that the mainte-
nance
work initiation and planning appeared
to be adequate;
noteworthy was the
increased
number of priority levels
assigned
to the work rather than grouping
all tasks within three or four priority levels.
This allows for more realistic
scheduling of maintenance activities.
The
inspectors
noted
that the planners
lacked specific qualification and/or
training requirements
~
The
1'icensee
should consider this area
as
one
which
they
may want to improve.
Overall,
the maintenance
work backlog
appeared
to be well controlled.
Since
this is
a
newer "plant with maintenance
work order s
no older than
1986,
the
inspector
noted
the potential
for the
backlog
to
become
greater
than
the
industry average.
The licensee
does
not have
a program to
manage
the
size of
the backlog;
the licensee felt restricting
the backlog to
a size limitation
may interfere with the
spontaneous
input of identified
problems
being
sub-
mitted.
The
inspection
revealed
duplicate
work orders
and
work that
had
been
completed; this had also
been
noted
by the licensee
in previous
reviews'.
The licensee
should consider periodically validating the content of the work
backlog.-
Maintenance
overtime controls appeared
to be inadequate;
a violation was ncted
in this area.
(paragraph 4.d.)
Labeling of plant equipment
and control of instrumentation
appeared
to be well
controlled.
This area is considered
a strength.
(paragraph
4.e
8 f.)
Maintenance
procedures
changes
are adequately
controlled, but the large
number
of "pen
and ink" advance
changes
could degrade
the readability of procedure
copies.
This is considered
as
a weakness.
(paragraph
4.g)
Maintenance
feedback report
program
and the repetitive fai lure program appeared
to be valuable
assets,
and
each is evolving.
When these
areas
become
comput-
erized,
the licensee will be able to track them in a more efficient manner.
Trip reduction
and personnel'rror
reduction
have
provided positive results,
and are considered
to be
a strength.
(paragraph 4.j.)
Overall,
the
Preventive
and Predictive
Maintenance
Programs
are in develop-
mental
stages.
Licensee
management
has
stated
that plans
and
schedules
for
implementing
additional
predictive
maintenance
activities will be developed.
The
lack of predictive
maintenance,
other
than vibration analysis
and
TS
required oil sampling,
was considered
an area of weakness.
(paragraph
4. 1.)
Inservice Testing:
LTOP; the licensee
tests
the
PORYs to ensure
low pressure
protection capability
by opening
the valves
then timing each
one
shut rather
than timing the valves
going
open.
The licensee's
actions
toward addressing
this potential
operability concern will be followed as
an
unresolved
item ".
(paragraph
4.m.)
- Unresolved
items are matters
which more information is required to determine
whether they are acceptable
or may involve violations or deviations.
The licensee
appeared
to conduct effective and disciplined management
meetings
to transfer
information
and control activities.
Also management
appeared
to
be intimately involved in daily activities.
Management
commitment to 'quality
is further noted in a
new gC initiative to verify system alignment.
REPORT DETAILS
1.
Persons
Contacted
Licensee
Employees
- R. Watson,
Vice President,
Harris Nuclear Plant
- W. Batts,
Maintenance
Supervisor
- - R. Biggerstaff, Principal
Engineer -
- J. Collins, Manage",
Operations
" G.
Forehand,
Director,
QA/QC
" C. Gibson, Director,
Programs
& Procedures
'
L. Hancock, Administrative Supervisor,
Harris Training Unit
" C. Hinnant, Plant General
Manager
" C.
Rose, Jr.,
QA Supervisor
- J. Sipp,
Manager,
E 8 -RC
" D. Tibbits, Director, Regulatory
Compliance
- R. VanMetre,
Manager,
Technical
Support
" M. Wallace,
Sr. Specialist
Regulatory
Compliance
- E.
Willet, Manager, Modification Projects
Other
licensee
employees
contacted
included
. Technicians,
Operations
personnel,
Maintenance
and
Instrumentation
8
Control
personnel,
and
office
personnel'RC
Representatives
W. Bradford, Senior
Resident
Inspector
M. Shannon,
Resident
Inspector
" Attended exit interview
Acronyms used throughout this report are listed in the'ast
paragraph.
2.
Operations
(71707,
71710)
Inspectors
performed direct and extensive
observations
of operational
and
control
room activ~ties.
Observations
were
made during
normal
and back-
shift hours.
Activities observed
included shift turnover briefings, the
use of control
room logs,
equipment
status control, the use of LCOs,
system
alignments,
ongoing maintenance
activities, surveillance
performance,
alarm
panel
status,
and the performance of operations
personnel.
Interviews
and discussions
were conducted with the Operations
Supervisor,
SF,
SROs,
ROs,
AOs,
STAs,
I8C personnel,
maintenance
personnel,
and
engineers.
a.
Control
Room and Plant Operations
/ (1)
Control
Room Decorum
Control
Room operations
were
observed
with an
emphasis
on the
performance
and conduct of operations
during
normal
and back-
shift hours.
There
were
no discernible
distractions
in the
control
room or around the control
room work stations.
Operat-
ing crews
were adequately
rested,
alert,
and
performed their
respective
duties
at their control
room work stations
in
a
competent
and
professional
manner.
The
number
of operators
in the control
room
were
in
accordance"
with= procedures,
met
the requirements
of
and
only licensed
operators
'anipulated
the
reactor
controls.
Communications
between
individuals
were clear,
including
face
to
face,
telephonic,
radio,
and the, public address
system.
Adequate
acknowledgement
of both audible
and visual
alarms
in the control'oom
was
observed.
The inspectors
noted
a constant visual vigilance was
in progress
at all times.
F
On several
occasions it was observed that managers
were present
in the control
room for certain evolutions.
(2)
Shift Turnover
Shift relief
and
turnover activities for various shifts were
observed
and
found to meet the requirements
of
and
OMM-002, Shift Turnover
Package,
Rev.
2.
These
turnovers
and
briefings included
SSs,
SFs,
supervising
operators,
ROs,
AOs,
stations
operators
and
other
operations.
personnel.
Shift
relief checklists
were
used
by personnel
and
were
reviewed
and
found to have
been
completed
and properly authenticated.
and operator s were
observed
completing
mandatory control
board
walkdowns
and
assuming
the required watch duties.
It was noted
that
maintenance
and
survei llances
in progress,
planned,
or
recently
completed,
were
adequately.
reviewed
between
the
shifts.
These
items were included in logs as being of interest
to shift personnel.
Shift
staffing
requi rements
for all
operating
positions,
including the fire brigade,
met the
technical
specifications.
A shift schedule
is available
to
each
individual
and easily
identifies positions, qualifications,
assignments,
and
upcoming
assignments.
remained
within the at-the"controls
area
as
required
by procedures
and Regulatory
Guide
1. 114.
Operators
exhibited
an
attitude
of competent,
well-mannered
professionals.
(3)
Logs and Records
'I
Control
Room
logs
are
maintained
and
completed
in accordance
with
and
AP-002,
Plant
Conduct
of Operations,
Rev.
3.
Log book entries
were
found to
be
neat
and legible.
The
entries
adequately
reflected
plant
status 'nd'bnormal
system
and
equipment
alignments
and
outage
information.
Log
book entries
were
made
on
a
real
time basis
and
were well
detailed
in that
they
showed
significant operational
events
- such
as
safety
related
system
alignment
alterations.
duting
plant evolutions;
Periodic
and daily reviews were accomplished
by staff personnel.
All of the, operator
stations
used
a blotter
size
pad
of
notations
divided
into
several
sections:
plant
status,
evolutions
in
progress,
concentration,
status,
nuclear
instrumentation,
and
secondary
chemistry,
safety
equipment
out of service,
and
unusual
lineup/turnover
items.
These
shift
information
sheets
were
very helpful to
an'yone
entering
the control
room area
in that the
sheets
provided
a
means
to quickly gauge
the status
of the plant
and
equipment
without requiring the operator to perform
a complete
accounting
of all
the
information
contained
on
these
sheets.
This
significantly reduced
the amount of time required to engage
the
operator
in discussions
of plant status.
These
sheets
were
also
very helpful
in assuring
that
a
complete
and
adequate
shift turnover
was performed.
The control
room
logs
also
benefited
from the
use
of these
sheets
in that
they
could
be
used
as
a cross-reference
to
verify the accuracy
or enhance
the details of the logs.
These
sheets
are kept for 30 days.
(4)
The use of these
plant status
sheets
was judged
a strength.
Status of Control Board
and Local Instrumentation
The
inspectors
ver'ified
by
observations,
interviews,
and
. research
that
measures
were
being
taken to pursue
the "black
board"
concept.
Basically,
- he
"b>eck
board"
referred
to is
the collection of annunciator
panels
above
the
main control
board.
Some
licensees
in
the
nuclear
industry
have
taken
initiatives to reduce
the
number
of lit annunciators
while the
Unit is at
power
thereby
making it easier
to identify off
normal
indications.
Management
interest
is
strong
in this
area.
There is
a requirement
that
a status
of the lit control
board
be reported daily to corporate
management.
This status
is then reviewed,
and when there are changes
in the
status,
a discussion
of these
changes
is conducted.
Operators
were
cognizant
of
the
control
board
status.
Those
that were disabled,
out of service
or lit were
logged
and
information accurately
reflected
the
board status.
Annunciator status
is also
a part of the shift
turnover package.
By observation,'he
inspectors
noted
that
there
is
vigorous
activity
and
management
involvement
in obtaining
the
"black
board" concept.
(5)
. Technical Specification
Compliance,
Regulatory Attitude
On Wednesday
September
9,
1988,
the plant
was in mode
5.
,The.
level
was
79
inches
below
the
reactor
vessel
=flange.
Considerable
work was in progress
in preparation
for
mode
4,
including work
on
the
S/G primary side drains.
During shift
turnover, further emphasis
and effort was placed
on work that
would
be
upcoming.
Additional maintenance
that
was
scheduled
for the day included: I) 'Naintenance'n
the
1A
EDG and;
2)
Work on the
1B SB inverters SII and SIY.
Requests
were in order
to al,ign the systems
so that work could proceed.
Several
per-
sonnel
on shift had concerns
as to whether this was appropriate,
considering
the plant conditions,
and if this
was
allowed
by
the TSs.
A discussion
took place
between
the
STA, the
on shift SCO,
and
the
SF.
An evaluation
of
TSs
showed
that
two
LCOs
were
in
question:
3.8. 1.2 which deals with AC power sou'rces;
and 3.8.3.2
which concerns
on site
power distribution.
Each
LCO requires
one train to
be operable
with the Unit in mode 5.
When evalu-
ated
alone,
each
LCO would have
been
satisfied.
The parties
engaged
in the
discussion
made
the
contention
that
the
same
train of electrical
power should
be
used to satisfy both
LCOs.
Conservatively,
this
would ensure
that
under all conditions
that: I) The facility could
be maintained
in its current
mode
of operation;
and
2) sufficient instrumentation
and
control
capability
would
be available
to monitor plant status.
Addi-
tionally, this would be in agreement
with the basis for section
3/4,8 of the TS.
The
SF discussed
these
concerns
with the Operations
Supervisor
and
the
Manag'er of Operations.
After further discussions,
the
decision
was
made to proceed with the
EDG maintenance
but to
defer the inverter work until
a later opportunity arose.
The
operators
discussions
and
actions
demonstrated
a
cleat
understanding
of and
adherence
to industry
regulatio'ns.
This
conservative
decision
to defer
the inverter work presented
a
prob1em
in that the
licensee
subsequently
suffered
a
loss
of
the
"A" train offsite
power
feed
during
the
scheduled
maintenance
when activities being
conducted
in..the
resulted
in the line being cut accidentally.
Details of this
event are contained
in
SOOR 88-2l6.
Clearance Activi,ties
Administrative
Procedure
AP-020, .Clearance
Procedure,
Rev.
2,
describes
the
methods
and controls
used
to effect clearances
on
plant
systems
.and
components.
The licensee
was at the
end of their
first refueling
outage
the first week of thi s
inspection
so
the
inspectors
had
ample
opportunity
to review
and
observe
clearance
activities.
The
operations
department
has
established
a
clearance
center
to
process
and
monitor maintenance
and surveillance activities during
the outage.
.This center is staffed
by. a
SS designee,
another
RC and
is supervised.
by
an
SRO acting in the capacity of Operations
Outage
Coordinator.
The area'here
the clearance activities take place is
located
opposite
the
control
room
entryway
vestibule
and
is
separated
from the control
room by the control
room access
door
as
well
as
a door leading
from the vestibule to the clearance
center
anteroom.
This separation
of activities contributed to
a very calm
and
well
ordered
control
room.
The
AO area
where shift turnover
meetings
were conducted is next to the clearance
center.
Activiti'es
in the
anteroom just outside
the two-clearance
center
windows were
usually conducted
by maintenance
technicians
requesting
clearances
to
be
placed
or informing the clearance
center that their work had
been
comp'leted
or
they
needed
post
maintenance
testing
to
be
performed, prior,to finishing their work.
The number of personnel
in
this
anteroom
was
never
excessive
and the activities being carried
out
were orderly.
Pages
over the
PA system for clearance
holders
and
maintenance
foremen.
for
the
purpose
of
verification,
clarification or approval
were
responded
to in
a timely manner.
Overall,
the
clearance
center 'functioned
well to
coordinate
the
activities
in the plant with the responsibilities
of the control
room while isolating the control
room operators
from the distracting
functions
of clearance
preparation
and
execution.
This
area
was
considered
to be
a strength.
The
inspectors
accompanied
several
different
performing
clearance
tagging,
independent
verification,
and clearance
removal.
Among
the
clearance
activities
observed
were
the
tagout
and
independent verification of the "B" EGG and the removal of clearance
tags
from the
seals
and drains
in the
containment.
Several
other
clearances
were noted
and audited during independent
walkdowns
of the Main Control Boards,
Containment
Pre-Entry
Purge
Exhaust,
Pumps,
Breakers,
CSIPs,
and
HVAC equipment.
No discrepancies
were
noted
between
the
notations
on
the
clearance
tags,
in the
clearance,
logs,
or
the
equipment
labelling.
Equipment
labelling
throughout
the plant,
with few exceptions,
was
judged
to
be
a
strength.
The
AOs performing the clearance
tagouts
and removals in
accordance
with AP-020
and
independent
verification in accordance
with PLP-702,
Independent Verification, Rev. l.
The
licensee
tracks
LCOs
out of the
Technical
Specifications
and
Fire Protection
Procedures
via OMM-003, Equipment
Record,
Rev.
2.
The
Equipment
Record
is
maintained
in
the
clearance
center
by the
SF designee.
A review of the
log
book
against
open
and clearances
demonstrated
that the licensee
was
maintaining. good control of their equipment status.
The licensee
uses
Caution
Tags
on equipment or components
requiring
special
instructions
or authority for their operation.
These
are
not
used
in the
place
of clearances
and
the violation of 'these
instructions
is
considered
sufficient
grounds
by the licensee
for
disciplinary
action.
AP-021,
Caution
Tag
Procedures,
Rev.
I
specifies
that
only Operations
personnel
are
authorized
to
hang
caution
tags.
A'.Cautioh
Tag
log is maintained
and audited
monthly
and
a
report
is 'ent
to
the
Manager
of Operations
noting
any
discrepancies
or any
tags
that
have
been
in place
for more
than
three
months
and why.
The Manager of Operations is required to sign
and date
the audit
form stating
the resolution of the outstanding
audit tags.
A review of the
Caution
Tag log and the audit forms revealed
that
the
. licensee
had
no
records
of
any
caution
tag
audits
being
performed
between
5/29/88
and
8/31/88.
AP-021
states
in section
5.4. 1
that:
Monthly,
the
Operating/Radwaste
Supervisor
shall
initiate
an
administrative
audit
of the
caution
tag
log.
The
failure of the
licensee
to
produce
documentation
indicating that
caution tag audits
were performed
between
these
dates is
a violation
(50-400/88-34-01).
The caution
tag audit
sheets
are
made
up of three
sections:
I)
a
list of discrepancies
resulting
from
a walkdown of all accessible
caution
tags
vice the controlled listing of the caution
tags that
operati'ons
maintains;
2)
a listing of all caution
tags that
have
been
in place longer than three
months
and the reason
they are
hung,
signed
by the
SF;
and 3) resolution of the tags listed in section
2,
signed
by the Manager of Operations.
While caution
tags
are
not as
safety
significant
as
clearances,
they
- still
serve
a
valuable
function and the proper control
and di sposition of these
tags
should
be
given
attention.
Specifically,
the
inspector
noted that
the
resolution
section
of
some of +he caution
tag audits
appeared
weak
and cursory.
Those
noted
were the audits performed
on the dates of
7/5/87,
3/28/88,
and 5/2/88.
This area of caution
tag audits
was
considered
to be
a weakness.
Overall,
the clearance
activities observed
by the inspectors
during
the
outage
were
judged
a
strength
of the
licensees
operations
department.
l
c., System
Walkdowns
Through observations,
the inspectors
verified the operability'f. an
System
by performing
a walkdown of the accessible
portions of
the
RHR system,
OP-. 111,
Residual
Heat
Removal
System,
Rev.
3,
and
Service
Water. System
Valve Lineups,
Rev.
3.
The inspector
confirmed that
the
licensees
system
lineup
procedure
matched
the
plant drawings
as well as the as-built configuration.
There were
no
equipment
conditions or items that would degrade
the performance of
the
system.
The interiors
of the electrical
and
instrumentation
cabinets
were inspected
to assure
that
no jumpers were installed
and
that cleanliness
standards
were
met:
The inspectors
verified that
valves,
including instrumentation
isolation valves,
and air operated
valves
were in the
proper
position, that
power
was available,
and
that
valves
were
locked
as
appropriate.
Both local'nd
remote
position indicators
were identified.
d.
Plant
Change
Requests
During the
inspection it was
determined
that the
were
being
reviewed
and
approved
in accordance
with technical
specifications.
The
were
being controlled
by established
procedures
and
the
reviews,
evaluations,
and results
were within previously established
criteria.
Operating
procedures
that
were affected
by
a particular
modification
were
changed
in
accordance
with
technical
specifications
and associated
drawings
were
changed
to reflect the
modifications.
The following PCRs were reviewed:
PCR 2318,
ALB-1
Containment
Unidentified
Leakage
(to
be
completed last quar ter 1988)
PCR 3517,
ALB-1 Miring Change
to Light Window (this change
was
in process
during the inspection)
PCR 2109, Wiring Containment
Narrow
Range
Level
PCR 1867,
ALB-2 Service Water Storage
Leakage
PCR 2595,
ALB-5 Component
Cooling Water Heat Exchange
Lo Flow
PCR 1866,
ALB-13 Source
Range
Loss of Detector Voltage Wiring
PCR 2589,
ALB-26 Axial Power Distribution System
The
above
PCRs dealt with the "black Board" concept.
The following
PCRs were also reviewed:
PCR 3419, Alarm Indication for S/G Nozzle
Dam Control Consoles
PCR 2389,
Eg Equipment Failures
PCR 3725,
RCS Main Loop Piping Wall Thickness
PCR 0502, Installation of
RCS Standpipe (for mid loop Ops)
The review of these
PCRs indicated that the licensee is maintaining
adequate
control over plant changes
and modifica'tions.
Housekeeping
PG0-003,
Housekeeping,
Rev.
2,
provi'des
guidance
to plant personnel
on the subject of housekeeping.
The
inspectors
took. note of the
cleanliness
and
orderliness
of various
areas
of the
plant during
walkdowns
and
tours.
,These
areas
included all,elevations
of the
auxiliary building, turbine building,
and
most of 'the
accessible
areas
of the containment building."
These
areas
were
observed
during'he
last three
weeks of the refueling outage.
The inspectors
did
not observe
any instances
where adequate
housekeeping
practices
were
not being
employed.
General
areas
and
pump
rooms
were uncluttered
and clean.
Leaking valves
or
system
drains
were attached
to floor
drains.
Instrumentation
cabinets
were exceptionally
clean
and free
of debris
or obstructions.
Portable
equipment
in the
plant
was
tagged
with information. identifying the responsible
individuals or
departments.
Some
control
problems
were
noted
(see
paragraph
4.n.), but the licensee
took rapid and adequate
corrective
action
on this issue.
Rooms or areas
where work was in progress
but
temporarily
suspended
had equipment
and materials
and drawings etc..
placed
away from the equipment
and out of the way of personnel
in
a
neat
and orderly fashion.
The
inspectors
consider
the
licensees
housekeeping
practices
and
efforts to be
a strength.
Operator Aids
Operator
aids
were
noted
to
be
in 'se.
OMM-001, Operations
Conduct
of Operation,
Rev.
4, clarifies
the
issuance,
use,
and
control of operator
aids.
Essentially,
aids
are
provided to assist
operating
'personnel
in the
conduct
of the',r duties.
Information
related
to
the
aspects
of
plant
operation,
safety,
and
administration
is
permitted
in
the
controls
area.
Put
+or the
actual
conduct of operations,
only specific
approved
aids
are to
be
.used.
Particular
care
has
been
taken to maintain current
and valid
operator
aids.
A containment
entry log book is maintained
in the
control
room during
modes
1-4.
This is to maintain accountability
and
control
of personnel
inside
containment.
The
use
of special
keys
under AP-504, Administrative Controls For Locked and Restricted
Rev.
2, are strictly adhered
to and maintained
for operators
use during emergencies.
A special
key holder with
a
key is available to operators
in the auxiliary building and is part
of the turnover
package.
If needed,
this special
key holder can
be
broken with the foot
and then
be
used
during emergencies
for the
entry and exit of secured
areas.
Overall,
operator
aids
were
noted
to
be properly controlled
and
approved.
Overtime
Technical
Specification
overtime
restrictions
are
detailed
in
OMM-001.
The limits dictated
in this procedure
and the requirements
of prior approval
by responsible
management
met the requirements
of
A reviewof operator
time sheets
from June
1988 through
September
1988 indicated
no instances
whe~e prior approval
had
been
required. 'owever,
the
licensees
TSs
and
procedure
states
that
'shift turnover time is excluded
from the overtime accounting.
While
this is considered
necessary
since
many plants are
on 12-hour shifts
(one of the
TS limits is less
than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any
48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period),
instances
were
noted
where
one individual
had
worked
28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> in,a
48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period,
and another
had worked
27 out of 48.
While these
were very isolated
cases,
the inspector
communicated that .they were
approaching
what
would
be
considered
a
reasonable
limit on
the
amount of time that could be expected
to be taken
as shift turnover
time.
The inspector
found the operations
department
control
on overtime to
be adequate.
Training and Required
Reading
The
inspectors
reviewed
the training that
had
been
given
to the
operators
on the
new fuel loading.
The licensee
is installing what,
is called Vantage
5 fuel and will be= running the
new core for twelve
months
in order to achieve
the
proper
burnup
so
that
they
can
install full
18
month
Vantage
5 fuel.
The
new
core
loading
has
several
advantages
and differences
from the
Cycle
1. core
load
and
these
items
were covered
in training given to the operators.
The
training also
addressed
the different method that will be
used to
-calculate
the Hot Channel
Factor enthalpy rise values
as well
as
a
higher
power defect.
This training
was formulated
and
conducted
by
the
Fuels
Engineering
Department
and
whi le
the training
was
not
observed,
the
study material
reviewed
demonstrated
a very thorough
approach
to the
preparation
of the
operators
for the
next fuel
cycle.
Surveillance Testing
The
inspectors
observed
and/or
reviewed
selected
operational
test
sur'veillances
to verify that:
1) there
were
approved
procedures
available for use;
2) test prerequi sites
wer e met; 3) admini strative
approvals
were obtained
before starting tests;
4) execution
of the
procedures
was
by qualified personnel;
5)
M&TE used for the tests
10
were properly calibrated;
6) data
and test results
were within TS
requirements;
7) test discrepancies
were dealt with immediately;
and
8)
the
systems
were
returned
to
an
status
within the
required time.
Direct
observation
of
the
performance
of tests
indicated
that
surveillance
test
procedures
were technically
adequate
to
perform
the required
testing
.
Surveillance
test
procedures
were present
in
the
testing
location
and
were
followed
step
by
step
during
performance;
completion
of the
steps
were
documented
by
marking
check off blocks (or initials and date),
as required.
Independent
verification
was properly performed
in accordance
with
PLP-702,
Independent Verification, Rev. I
Surveillance
testing
was
conducted
in
accordance
with
the
requirements
of
PLP-103,
Surveillance
and Periodic Test Program,
Rev.
3.
These
included:
Pretest activities:
Procedures
were
reviewed prior to starting
work,
the
required
MITE obtained,
SF/supervising
operator
authorization
obtained,
and
a discussion
of the test
and its
effect
on the plant was held.
Post
test
activities:
Procedures
were
reviewed
by the test
.
performer
for completeness
and
accuracy,
the
SF/supervising
operator
reviewed
the test for completion,
and
the final
review completed.
Tests
were
suspended
when required in order to notify the
SF of
a test deficiency, or to correct procedural
deficiencies.
Test performers
were knowledgeable
of the equipment
being tested
and
demonstrated
a good understanding
of the testing process.
Very good
communications
and close coordination
was observed
between
the plant
operators
and the test performers.
Parts,
components,
or materials
used
by
personnel
during
these
scheduled
surveillance
testing activities were
found to be properly
documented
on the associated
implementing
work requests
and in the
surveillance
test
procedures.
The appropriate
part identification
information was found to be recorded
where
required
(material
code,
requisition
on store,
lot,
batch,
model,
serial
number, etc...).
Equipment,
components,
or parts
removed
from the immediate work/test
area
were being correctly identified by an equipment
removal tag.
t
The periodic performance of surveillance tests did result in several
temporary
procedure
changes
and/or
procedure
revisions.
It appears
that
implementation
reviews
are
effective
in
satisfying
the
licensees
two year
review criteria.
The
licensee
requires
that
a
review of procedures
be conducted
every two years
in accordance
with
AP 005,
Procedure
Review and Approval,
Rev.
4.
However,
there is
a
concern
that the
number of existing
temporary procedure
changes
and
the extent of these
changes
might lead to confusion or errors
by the
test'performers.
This concern will be part of an inspector followup
item (400/88-34-04)
paragraph
4.g.
Based
on the surveillance
procedures
reviewed 'and/or reviewed, test
procedures
are
adequate
to satisfy
the applicable
requirements
and
commitments.
Surveillance
activities
are
documented
in accordance
with applicable
program requirements.
The following surveillance
procedures
were observed
and/or
reviewed:
OST-1029,
Containment
Outside
Isolation
Valve
Verification, Rev.
2
OST-1215,
Emergency
Service
Water
System Operability Quarterly
Interval
Modes 1,2,3,4,
Rev.
1
OST-1315,
Emergency
Service
Water
Valve
Test
Two Year
Interval
Modes 5,6,
Rev.
2
OST-1024,
Onsite
Power Distribution Monthly Interval Verifica-
tion Modes 1,2,3,4,5,6,
Rev.
1
OST-1045,
ESFAS Train
B Slave Relay Test Quarterly (on staggered
test basis)
Modes 1,2,3,4,
Rev.
2
OST-1069,
Containment
Building
Inside
Manual
Isolation Valve Verification, Rev.
1
OST-1081,
Containment
Visual
Inspection
Prior to Establishing
Containment
Integrity
and After Each
Containment
Entry
Where
Containment Integrity is Established,
Rev.
0
OST-1216,
Component
Cooling Water
System Operabil ity (1A SA and
1B
SB pumps in service),
Rev.
2
OST-1108,
Pump Operability Quarterly Interval
Modes 4,5,6,
Rev.
3
Potential
Reportable
Events
An inspector
reviewed
the following SOORs.
These
SOORs were chosen
for review because
they were not reported
and required review by the
licensee
to verify that they fell outside of the requirements
of 10 CFR 50.73.88-024,
Tornado
Damper Installed Backwards;88-020,
Overdue
Maintenance
Surveillance
Test;88-028, Incorrect
Steam
Dump System Wiring;88-102,
Mixed Grease
in "B" CSIP alt Miniflow Iso Valve;
12
88-135, Failure to make I Hr. report when both
NDAFW Pumps were
The inspectors
review of these
SOORs revealed that the licensee
had
taken
proper
actions
in the
review
and disposition
of the
above
noted items.
k.
Contai-nment Closeout Inspection
An inspector
accompanied
licensee
personnel
on
one of the final
containment
closeout
inspections.
The
AO performing the inspection
needed
to take
loop readings
and inspect
the elevator
service
room at the top of the elevator
shaft.
The
containment
had
been
noticeably cleaned
up since the first week of inspection
and overall
appeared
to
be in very
good condition.
The elevator
service
room,
upon
inspection,
was
found
to
have
drawings,
tools,
and
other
materials
from previous
maintenance
activities left about
the
room.
The
AO made
note of this and arranged
to have the
room cleaned
out.
An inspection of the
sump areas
revealed
some lead blanket shielding
lying on the floor within 20 feet of the
sump intake.
While it is
unlikely that
these
blankets
could
be
swept
up against
the
screens,
the licensee
agreed
that they should
be
moved outside of
containment
and
made plans to accomplish this.
Overall
the
in0pectors
review
of
the
licensees
closeout
of
containment
revealed
that
they
were
taking
adequate
measures
and
pe~forming
thorough
inspections
of the
containment
in
order
to
satisfy
cleanliness
standards
and
long term recirculation
accident
analysi s.
No additional
violations
or deviations
were
noted
except
as
noted
in
paragraph
2.b.
3.
Emergency Operating
Procedure
Review (42700)
The inspector
observed
licensed
operator s perform the actions prescribed
by the
and
Paths for a
SGTR with loss of reactor coolant,
subcooled
recovery.
The
and Flowpaths
used for the scenario
were:
Path
Two
With
Loss
of
Reactor
Coolant:
Subcooled
Recovery,
Rev.
2 5,3
Faulted
Isolation,
Rev.
2
The
operator
actions
were
satisfactory,
procedural
compliance
was
good
and the
were
found to
be
adequate
for the limited depth of these
observations.
At
the
conclusion
of
each
scenario,
the
simulator
13
instructor
systematically
and
thoroughly critiqued
the
actions
of the
operating
crew.
These critiques were conducted
in a professional'anner,
were frank, well received,
and
made
a positive contri,bution to operator
training.
was walked
down in the control
room
and the plant areas
to
ensure
the
equipment
necessary
for operation
could
be
accessed
and
the
nomenclature
in
the
procedure
and
the installed
plant
labeling
was
consistent.
No deficiencies
in the
portions
of the
observed
and
walked down were noted.
No violations or deviations
were identified.
4.
Maintenance
Support of Operations
(62700,
62702)
An
evaluation
was
performed
on
the
licensees
maintenance
program.
Specific
areas
addressed
were repetitive failure identification,
root
cause
analysis,
and the interface with the operations
department.
During
the inspection effort the inspectors:
conducted
interviews with workers
and supervisory
personnel;
reviewed station
maintenance
procedures,
work
requests,
maintenance
backlog,
completed
maintenance
"work packages,
and
maintenance
experience
reports.
They
also
analyzed
the
maintenance
planning
and
scheduling
process,
and
the
preventive
and
predictive
maintenance
programs.
a.
Maintenance
Work Initiation and Planning
The licensee
used
a 'computerized
system for WR/JO processing,
with
numerous
terminals
located
throughout
the plant
and offices.
This
system
was described
in the last
SALP report
as
an area of str'ength
and
has
continued
to
be
so.
The
inspectors
reviewed
procedure
MMM-012, Maintenance
Work Control
Procedure
(Automated
Maintenance
Management
System),
Rev.
6.
MMM-012 included
a description
of WR/JO
initiation,
approval,
prioritization,
planning,
execution,
and
postwork action.
Under this
AMMS system,
all
work performed* by
maintenance
personnel
was
accomplished
under
a
WR/JO,
including
preventive maintenance.
Any plant
employee
who discovered
a deficiency witt p>ant equipment
is directed
by procedures
to
hang
a Deficiency
Tag
and initiate
a
work request,
by entering
information into
a
computer
terminal.
After review and approval
by a Shift Foreman or Supervisor,
the
WR/JO
was to be processed
by the maintenance
planners.
Priority assigned
to
the
WR/JO
was to be determined
by the Shift
Foreman
except
for specified
non-safety
equipment.
The priority
system
included
17 priority levels
and
8 work condition
codes
which
specified plant condition required for work to be performed.
To
assess
the distribution
of priorities
among
WR/JOs,
a daily
printout titled
"Yesterday's
Work
Orders",
dated
9/20/88,
was
reviewed.
Among the
66
new work orders in this printout,
13 of the
17 priority levels
were
used.
The
most frequently
used priority
/ was
26 (the priority levels
are
not consecutively
numbered),
which
occurred
nearly
a third,
(21 of 66),
of the
work orders.
This
appeared
to be superior to a typical priority system using only 4 or
5 priorities, wherein
one priority level
may
be assigned
to
as
many
as
80% of the work orders.
With the
17 priority levels,
instead of
4 or 5, the responsibility for the determination
of which MR/JOs to
work on first was primarily with the shift foremen,
rather
than with
the planners
and maintenance
crew foremen.
Interviews with planners
and maintenance
foremen
gave indication that assigned priority levels
i:ere being
used for scheduling
work, with higher priorities
being
planned/worked
ahead
of
lower priorities.
The
expanded
priority
system
appeared
to be
an area of strength.
Planners
were organized
in
a separate
group within the maintenance
department.
New planners
were typically selected
from first class
technicians
(mechanical/electrical/I&C).
No formal planner quali fi-
cation or training
program existed at the time of this inspection.
'pproximately
5 of the
10 planners
had
been
through basic
systems
training,
and
5 of the
10
had attended
classroom training in
EQ,
ISI/IST,
PMT,
Q list, fire protection,
and security.
Additionally,
planners
had
attended
occasional
(approx.
3 to
6 per. year)
group
discussions
conducted
by the planning manager,
which covered
various
subjects
including
"lessons
learned."
Although
no
per formance
deficiencies
were
observed,
the
lack
of qualification/training
requirements
for planners
was considered
an
area which the licensee
may want to strengthen.
b.
Maintenance
Mork Backlog
r
The
maintenance
wor k backl og
appeared
to
be
wel 1 control led.
The
WR/JOs were well prioritized and the size of the backlog
as indicated
by the percentage
of non-outage
WR/JOs greater
than
90 days
old was
52%.
Total
MR/JOs
outstanding
were
approximately
4800,
of which
approximately
2600
were
non-outage.
Since this
was
a
newer
plant,
with no
MR/JOs older than
1986,
the inspectors
noted
the potential
for the backlog to
become
greater
than
other
much older facilities
inspected
by the
NRC
as
the plant ages.
The -licensee
stated
the
position that ~either the size of the backlog nor the.age
of individ-
ual
MR/JOs (especially
low priority) were
of concern.
They felt
restricting
the
backlog to
a
size
limitation
may interfere with
the
spontaneous
input of identified problems
being submitted.
The
licensee's
program
was to properly prioritize MR/JOs,
then work them
in order of priority without regard to age.
To aid in monitoring the
maintenance
department
performance,
weekly
management
reports
had
been
generated,
including:
number of WR/JO
initiated,
maintenance
planning backlog
(number of WR/JO unplanned),
and
maintenance
manhour
backlog
(manhours
of corrective
maintenance
and
PM/ST/PT,
compared
with available
manhours),
The
manhour
backlog report appeared
to be
an effective management
tool.
15
The maintenance
department
had
no formalized goals for controlling
.
the
amount
of maintenance
work backlogged.
Also, there
was
no
formal
maintenance
department
plan for reviewing old
MR/JOs,
to
prevent
an accumulation of "breakdowns
in the system".
However,
the'echnical
support
department
stated
they
had
looked at all
open
WR/JOs prior to the current
outage.
The inspector
reviewed
twelve
open
WR/JOs
on
safety
equipment
that
were
on
hold for various
reasons:
three
from 1986, five from 1987,
and four from 1988.
No
operability concerns
were identified
among
them.
However,
two of
them could
have
been
completed
or at least
removed
from hold prior
, to this inspection,
and
one
had actually
been
previously
completed
but not closed,
under another
WR/JO:
MR/JO
86-BK(}El (priority 26)
was
on
hold for parts.
The
pr'oblem
was
a missing junction
box
cover for lED-161.'alve
was the hydrogen
cover gas inlet to the reactor coolant
day
tank.
It
was
located
outside
containment,
and
was
a
containment
isolation
valve'.
On
review
by the licensee,
the
cover
was not considered
to
be required for Eg.
However,
the
inability to
obtain
a junction
box
cover
in
two years, is
questionable.
WR/JO
86-BDFP1
(priority 26)
was
on
hold for parts..
Four
screws
and
one clip were missing
from
a junction
box
on the
side of Hydrogen
Recombiner
A, located
inside containment.
On
a review and inspection
by the licensee,
this work was found to
have
been
previously completed
under
another
WR.
Accumulation
of old duplicate
could
tend
to
make
the
backlog
more
difficult to review.
MR/JO 87-BLFF1 (priority 7)
was
on hold awaiting response
on
a
feedback
report.
Vibration of the
emergency
filtration fan
motor for the control
room area
ventilation
had
been
measured
and
found
to
be
excessive.
Vibration
testing
had
been
accomplished
per
OST-1131,
Control
Room
Area
HVAC,
System
Inservice
Inspection
Test,
quarterly Interval,
Modes at All
Times,
Rev.
1.
Acceptance
criteria
for
OST-1131
stated:
"Vibration measurements
taken for
commitment.
Does
not
affect Tech.
Spec.
operability.
Does
not affect passing
OST.
If vibration exceeds
limit, initiate
a
NMR."
This
WR was for
troubleshooting
the
motor
to
determine
the
cause
of
the
vibt ation, ie:
needs
grease,
bolting not tight, frame supports
loose,
or bearing failure.
The lack of corrective
maintenance
for
one
year
appeared
to dilute
the
effectiveness
of
the
vibration
measurement
effort.
The
purpose
of
vibration
measurements
are to predict the early failure of machinery,
and
allow repairs prior to failure.
While there
was not an overly large backlog of old WR/JOs,
management
review to identify and correct "system breakdowns" will be needed to
prevent the accumulation of such
a backlog.
In addition to the lack
of
goals
for
corrective
maintenance
backlog,
the
maintenance
16
department
lacke'd other
performance. goals,
such
as:
ratio of pre-
ventive to total
maintenance,
preventive
maintenance
items
overdue,
maintenance
rework, staff .turnover rate,
or unavai labi 1'ity of safety
systems.
The licensee 'stated
maintenance goals're
being developed.
c
~
Maintenance
Scheduling
To
assess
the
licensee's
work scheduling
during
the
outage, .the
inspectors
interviewed
Outage
and
Maintenance
Department
personnel
and
reviewed
scheduling
charts
and reports.
Outage
maintenance
and
modification work was 'scheduled
by the
Outage
Department
with the
use
of
an
Artemus
computer
program.
- The
program determined
which
jobs were critical path,
and the proximity of each
job to becoming
critical
path for the
outage.
Also, a'harted
schedule
of all
major/poten~ial critical path work items was maintained
on
a wall in
the
outage
center.
Daily outage
reports
were
published,
showing
the current status of all outage
modification
and major maintenance
work.
These daily reports
were
used in,the licensee's
daily outage
meetings.
Also weekly charts
were published,
showing overall
work
status
including
number
of
MR and
manhours
(active
and completed)
for CM and
PM.
Additionally, weekly charts
of status
were
kept for
each
maintenance
work crew to identify any crew that
was falling.
behind schedule.
The Maintenance
Department
also
had
a separate
outage
coordination
room, with assigned
personnel,
ANMS computer terminals, wall charts,
and
telephones.
There
was
no link between
AMNS and
Artemus,
so
manual
entries
into Artemus were required.
The licensee
stated that
the establishment
of
a link between
ANNS and
Artemus
was
planned.
Overall,
the
outage
work scheduling
and coordination
ap'peared
to be
adequate.
,d.
Naintenance
Overtime
Controls
on working hours of key maintenance
personnel
who perform
safety related
functions
are required
by TS,and
by MNN-001, Mainte-
nance
Control
of Operations,
Rev.
2.,
Authorization
by the
Plant
General
Manager
or his designee
is required for any deviation
from
the following guideline limits on work hours:
1.
16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight
2.
16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period
3.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per'iod
4.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any
7 day period
5.
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> break between
work periods
TSs
and
MMN-001 also required that individual overtime be'eviewed
monthly by the Plant
General
Manager or his designee
to assure
that
excessive
hours
had not been
assigned.
17
The inspector
reviewed
records
of maintenance
work hours for three
crews
(one mechanical,
one electrical,
and
one
IEC) that worked
on
safety
systems.
Records
for pay
periods
covering July
30,
1988
through
September
9,
1988
were
reviewed.
During
most
of thi s
time,
the plant
was in
an outage.
Each'f
these
crews
contained
- approximately
ten
maintenance
technicians.
The
number of instances
identified where guideline limits were
exceeded
were:
12,cases
of
exceeding
24. hours
in 48,
18 cases
of exceeding
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days,
and
no cases
of exceeding
the other guideline limits.
The licensee
had records
indicating Plant
Manager
approval
for six of the
cases
where
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in
7 days
was exceeded.
However, the l.icensee
stated
that
no
approvals
had
been
given for the
remaining
12
cases
of
exceeding
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days or the
12 cases
of exceeding
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
in
48
hours.
The
12
cases
of exceeding
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
in
7 days
were
subsequently
provided written approval
by the
Plant
Manager
along
with
10 additional
cases
that
were identified by the licensee, 'for
exceeding
this limit without approval
during
the
period July
30
through
September
16,
1988.
The inspector
noted that
some of the
Plant
Manager
approvals
did not satisfy
TS overtime
requirements
(see
attachment
1).
Based
on the
above
records
review and interviews with three mainte-
nance
foremen
and the
maintenance
manager,
the inspector
concluded
that the 'licensee
had
a program in effect for control of maintenance
overtime that in practice did not comply with
TS or
MMM-001. It
consisted
of obtaining written Plant
Manager
approval for exceeding
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
in any work week.
One maintenance
foreman
was not aware
that
there
were limits
on
maintenance
overtime.
TSs
and
MMM-001
guideline. limits, which were
based
on other
than
a work week,
were
,not controlled by written approval.
The instances
of exceeding
TS workhour guidelines without authori-
zation
were
not identified during
a
monthly
review of individual
overtime records;
the review is required
by the
TS.
The licensee's
failure to comply with TS requirements
which requires
authorization prior to deviating from the maximum workhour guidelines
for key maintenance
personnel
is
a violation (50-400/88-34-02).
Labeling of Plant Equipment
During inspector
walkdowns in the plant, labeling was observed to be
very
good.
With few exceptions,
all valves,
switches,
breakers,
components,
and
doors
were clearly
labeled.
On
valves,
durable
metal
tags
were
attached
with heavy
wires.
On electrical
cabinets,
doors,
and
other
components,
color coded plastic labels
were
affixed.
To
accomplish
the
labeling
task
the
maintenance
department
had
assigned
one
person
overall
responsibility
for
labeling.
Also, the
maintenance
department
had the ability to
make
and install
labels
in
a matter of hours.
The licensee
stated that,
by using 'onsite
computerized
machines,
metal
tags
could
be
made
in
. about
one
hour
and plastic labels within about four hours.
Overall,
plant labeling is considered
to be
an area of strength.
Control of Instrumentation
Valves
The control of instrumentation
valves for safety related
equipment
appeared
to
be well established.
The instrumentati on .valve
were
well labeled.
Valve positions
we'e
controlled
by the
maintenance
department
by using
maintenance
special
procedure
SPP-0005,
Instru-
ment Venting and Isolation
Valve Lineup Procedure,
Rev.
2'.
SPP-0005
was very clear
and complete,
including valve locations
and one line
diagrams
showing
valve
arrangements.
Also,
the
accomplishment
of
SPP-0005
was
included
as
a prerequisite
for plant heatup
in plant.
general
operating
procedure
GP-002
Normal
Plant
Heatup
From
Cold
Solid to
Hot Subcritical
Mode
5 to
Mode 3,
Rev.
3. Overall,
the
control of safety related instrumentation
valves
was evaluated
to
be
an area of. strength.
Maintenance
Procedures
While
reviewing
maintenance
department
procedures,
the
inspector
noted that
some
procedures
contained
a
number
of Advance
Changes.
One
procedure,
MMM-001, contained
12
Advance
Changes
dating
from
. January
23,
1986 to August
19,
1988.
An Advance
Change
could
be
handwritten
or typed.
Some of the handwritten
Advance
Changes
were
observed
to provide. poor copy quality.
While all of the
procedures
reviewed
by the inspectors
were readable, it appeared
that the
use
of large
numbers
of handwritten
Advance
Changes
could
degrade
the
readability of procedure
copies.
According to AP-007,
Temporary
and
Advance
Changes
to Plant
Proce-
dures,
Rev.
6,
an
Advance
Change
is
an expedited- modification that
may change
the intent of the procedure.
It requires
the
same
review
and
approval
as
a procedure
revision.
An Advance
Change
was to
be
issued
as
a
page
replacement
in the original procedure,
including
a
new "list of effective
pages".
A procedure
revision differed from
an Advance
Change
in that it was typed,
a complete
new procedure
was
,issued,
and it required
a formal review of the entire procedur'e.
An
Advance
Change
does
not require
a complete
procedure
review.
Administrative Procedure
AP-006,
Procedure
Review and Approval,
Rev.
8, requires
that plant procedures
be
reviewed
at least
every
two
years
(periodic procedure
review was also required
by ANSI 18.7
and
Technical Specification 6.8.2).
AP-006
requires
that
during this
two year
review
Advance
Changes
are
to be'ncorporated
into the
procedure
as
a
new revision,
or cancelled.
AP-006 further
notes
that
any required
revisions
should
be initiated and approved within
45 days of the end of the anniversary
month of the
two year review.
The
licensee
stated
and
the
inspector
independently
verified that
all required
two year
reviews
of maintenance
procedures
had
been
done
on
schedule.
However,
the
inspector
noted that there
was
a
19
large
backlog of required
revisions that were overdue,
based
on the
two years plus
45 days requirement of AP-006.
Overall, approximately
700 of the 2400'maintenance
procedures
were overdue for revision.
The licensee 'stated that all of these
procedures
overdue for revision
were
useable.
Further,
any
needed
changes
identified by the review
process
did not affect the technical
accuracy
of the procedure
and
'ad
no safety significance.
A spot
check
by inspectors
identified
no overdue revisions that had safety significance.
In
summary,
the
inspectors
observed
that
handwritten
changes
to
p. ocedures
could
degrade
the readability
of procedure
copies,
and
use
of them
should
be
minimized.
The
large: backlog
of
overdue
procedure
revisions
was
considered
to
be
a weakness'he
licensee
stated
that
a
plan
to
reduce
the
backlog
of
overdue
. procedure
revisions
would be developed
soon .
This is identified as inspector
followup item (400/88-34-04).
h.
Maintenance
Feedback
Reports
The inspectors
reviewed
MMM-026, Maintenance
Feedback
Report,
Rev.
0,
and
interviewed
Maintenance
Department
managers,
foremen,
and
technicians.
The maintenance
'FBRs provided
a
system for technician
feedback
to maintenance
engineers
to ide'ntify and obtain resolutions
for problems
encountered
in the field.
The
maintenance
engineers
would
involve
systems
engineers
from
the
Technical
Support
Depar'tment
when necessary.
A maintenance
FBR coordinator
had
been
assigned,
who received
and
tracked the status of all
FBRs.
Each
FBR was assigned
to,an engineer
for action, with r'equi red completion date.
Over
4000
FBRs
had
been
initiated during the period of 1986 through September
28,
1988.
The
majority of these
had
been
completed,
with written answers
sent
back
to
the
originators.
The
six maintenance
technicians
interviewed
were all sati-sfied with the effectiveness
and
responsiveness
of the
system.
The inspector
reviewed
65
FBRs in the master file from January
1988.
Of those,
10 were still open,
41 resulted
in
a procedure
change,
7
resulted
io
a
PCR,
and
7 required
no
change
but had
an answer
back
to the initiator.
At the time of this inspection,
the licensee
had
a file of all
FBRs, but did not monitor overall status of FBRs,
such
as
backlog,
relative
importance,
or
age.
The
licensee
stated
an
intent to prioritize and computerize
the
FBRs by June
1989.
Overall,
the inspectors
considered
the maintenance
FBR system to be effective
and
an area of strength.
However, the planned
improvements
in priori-
tization and management
are
needed.
20
Repetitive Failures
The inspectors
reviewed the licensee's
program for repetitive failure
analysis.
The responsibilities for analyzing
equipment
work records
were outlined in MMM-012, Maintenance
Work Control Procedure,
Rev.
6.
The
instructions
for handling repetitive failures
when identified
are
contained
in MMM-013, Maintenance
History Records,
Rev.
5.
The
inspectors
conducted
several
interviews with personnel
responsible
for identifying and resolving repetitive failure problems
including
maintenance
planners,
maintenance
engineers,
and
Technical
Support
engineers.
The maintenance
planners
utilized the
WR Planning
Function of
AMMS
to review and plan work requests.
The planner studied the
equipment
history by entering
the
component
tag
number to call. up all WR/JOs
related
to that
component
tag
number.
Then the planner
determined
if a
WR/JO
indicated
repetitive
or mu'ltiple related
equipment
failures.
Repetitive
Failures
would
be
entered
into
the
Repair
Instructions
and
a copy of the
WR/JO are
forwarded to the Project
Engineer-Maintenance
for action.
If the planner did not rec'ognize
the fai lure
as repetitive,
the
maintenance
crew could
request
a
failure analysis
by initiating
a
MFBR in accordance
with
MMM-026,
Maintenance
Feedback
Report,
Rev.
0.
This report
would be
sent to
the Project Engineer-Maintenance,
who reviews the
FBR for corrective
action
and assigns
a Project
Reviewer.
At the
same
time,
the
crew
secured
the failed components
to aid the maintenance
engineer
in the
analysis.
The findings and resolutions of the
FBR are documented
on
a B/RFIR by the maintenance
engineer.
The
B/RFIR is
included
as
part
of
the
maintenance
equipment
history,
when it
has
been
determined
to be
a repetitive failure.
If a plant modification
was
required to resolve
the problem,
the
maintenance 'ngineer
initiates
a
in accordance
with AP-600,
Plant
Chanqe
Request,
Rev.
4.
The B/RFIRs are tracked to completion
by the
cognizant
maintenance
engineers.
A monthly status
report
,showing
all
outstanding
B/RFIRs
and
identifying action
document
status
(PCRs)
is distributed
to
the
maintenance
engineers.
The
maintenance
engi neer s could request
Technical
Support
engineer s to
determine if the repetitive failures indicated
a trend,
Also, to
determine if there
had been
a significant
number
of fai lures
due to
a particular
cause,
a report
from the
CHF is
generated
monthly.
This report listed the keywords for causes
of failure and the
number of occurrences
that
month.
If a specific
keyword
came
up
often in
a particular
month,
an investigation
was initiated.
This
ensured
failure
mechanisms
were
investigated
across
system
boundaries.
21
The inspectors
noted
a
number of areas for potential
improvement in
- the
licensee'
repetitive fai lure analysis
program,
as
described
below:
There were
no specific instructions
as to what defined
a repeti-
tive failure.
The procedures
instructed
the planners
on what
to
do
when
a repetitive failure
was identified,
however,
no
guidance
was
given
in
the
determinat'on
of
the
repetiti.ve
failure.
The inspectors
interviewed planners
from mechanical,
electrical
and 'IKC.
The mechanical
planning
group
w'as struc-
tured
such that the planners
were divided to have responsibility
for certain
bu'.ldings.
The
mechanical
planner
interviewed
indicated that
no time'imit existed in his determination of a
repetitive fai lure.
This means that any similar fai lure in the
past,
no matter
how much time had elapsed,
could be determined
as repetitive.
The
inspectors
queried
as
to
how
many
past
failures
constituted
a repetitive
fail.ure determination.
The
planner
indicated there
was
no set
number,
but
he relied
on
his experience
in making, the determination.
The
I8C planners
were divided by plant systems.
The
IKC planner
also relied
on
experience
in determining
a repetitive failure.
The
IKC planner
interviewed indicated that
no specific time frame
was involved
in the repetitive fai lure determination.
There
was
only
one electrical
department
planner,
therefore,
all
the electrical
related
WR/JOs
were
p'lanned
through
one
person.
The
electrical
planner
differed
from
the
other
planners
interviewed
in that
his criteria for
a repetitive
failure involved previous failures within the last six months
to one year.
He also
indicated that the similar failure would
have
to occur
two or three
times within the
time period in
order to be determined
as repetitive.
The lack of specific
guidance
in repetitive failure determina-
tion
was
also illustrated
in reviewing
numerous
8/RFIRs for
the past
two years.
In
some
cases,
a repetitive failure
was
identified after
only
one
similar occurrence,
while in other
cases
a B/RFIP was not initiated until numerous
similar failures
occurred.
Failure
mechanisms
in similar components
installed in different
systems
may not
be identified
as repetitive.
The maintenance
planners
routinely
reviewed
the
component
failure history
by
entering the component
tag
number.
However,
since it was time
consuming,
the part
number
was
not routinely entered to review
'the
past
history.
Therefore,
a similar
problem
in
another
system
may
have
existed
but it
was
not identified.
The
licensee's
method for determining
these
type of failures
was
provided
by the monthly
CHF report of keywords for the
causes
o'f failures.
The inspectors felt that
the
CHF report
may not
provide
the
information necessary
to identify repetitive
past
failures across
system
boundaries.
'The report only listed the
22
keywords
for causes
of failure for that
month.
Therefore, if
a simila~ failure occurred previous to that
month, it could
be
overlooked.
Another
problem
was
the
use
of the
keywords
to
initiate
an investigation
across
system
boundaries.
Although
the planners
entered
the keyword from the approved
keyword list;
the
use
of
keywords
depended
upon
the
individual
planner's
preference.
Two
planners
could
use
different
keywords
to
describe
the
same
problem - therefore,
a
failure
mechanism
across "system
boundaries
might not
be identified when the
monthly report was reviewed
because different keywords were used
for a similar problem.,
4.
The monthly status .report of B/RFIRs distributed to the mainte-
nance
engineers
did not contain,
pre-1988,
outstanding
B/RFIRs.
The inspectors
noted that although
143
1987 B/RFIRs were open,
they
were
not
included
in
the
monthly
status
report.
The
Project
Engineer-Maintenance
indicated
that
he
occasionally
reviewed all open B/RFIRs and informed the cognizant
maintenance
engineer of old B/RFIRs to ensure
action
was being implemented.
The
inspectors
noted
a
concern with repetitive fai lures that
had
a
PCR submitted for two years
and
no action
had
been
taken
to correct
the
problem.
The
example
noted
was with mechanical
seals
on the Goulds
3196
ST and Crane
Deming 3065 A05 pumps.
In
the past
two years,
each
has
accounted
for 28 mechanical
seal
~ failures throughout different systems.
Two fai lure mechanisms
were identified; the first was shaft deflection
and the
second
was that the stuffing boxes didn't have sufficient clearance
for
proper flushing
and cooling.
Since
these
failures were
on non-
safety related
pumps,
the
PCR received
a low priority.
However,
the
continued
failure of these
seals
resulted
in increased
radioactive
contamination
in
some
areas
and
an
increase
in
Man-Rem exposure.
In the
PCR priority system,
no time period
to
implement
the
modification
was
delineated.
This
could
result
in
a repetitive
problem like the mechanical
seals
being
repeatedly identified by plant personnel
and not being
pursued
in
a timely manner.
In the
case
of the mechanical
seals,
the-
maintenance
department
issued
an
IPBS
Form in order to
achieve
some action
on this issue.
This form was
a request to
planning
and budget'ersonnel
to allow installation
of
the
recommended
actions.
The
Planning
and Scheduling
group
could'ccept
or reject the proposal.
This could lead to the
PCR never
being
implemented,
or not
being
implemented'or
a
long time
period.
This process
appears
to
be
cumbersome
for getting
low
priority repetitive failures resolved.
The
licensee'
program for tracking
and
resolving
r'epetitive
failures
had generated
approximately
254
B/RFIRs over the past
two years.
A total
of
85 'PCRs
had
been
written
and
30 of
those
had
been
implemented
at
the
. time
of the
inspection.
The
licensee
was
in the
process
of computerizing
the
B/RFIR
program to aid in the tracking of unresolved
issues.
Overall,
the B/RFIR program
had produced
some positive results.
23
Trip Reduction
and Personnel
Error Reduction
In
September
1987,
the
licensee
developed
procedure
PLP-109,
Trip
Reduction Assessment
Program,
Rev.
0.
The primary objectives
of the
TRAP
were
to
provide
a
formal analysis
of the root
causes
for
related
trips
and
to
recommend
preventive
measures
to
prevent
recurrence.
The
secondary
objective
was the root cause
evaluation
for non-trip related
LERs.
The
TRAP
subcommittee
was
made
up of
personnel
from
operations,
maintenance,
safety,
human
factors
.regulatory compliance,
NSSS vendor representative,
technical
support
and
Inciden't Investigation
Group
Representatives
The
subcommittee
met quarterly or
as
directed
by the
PNSC
tc
review plant
SOORs,
LERs,
Incident
Reports,
Post
Trip Reviews,
and reports
describing
events
at
other
plants.
The
minutes
of ,these
meetings
were,
forwarded
to
the
PNSC
by the Manager-Technical
Support.
The
PNSC
formally assigned
any recommended
actions
which were tracked
by
as
PNSC action
items.
The
TRAP subcommittee
also
helped establish
plant goals.
The
1988 goals
and results
up to September
9,
1988,
are listed
below:'ARAMETER
GOAL
ACTUAL
Unplanned Trips
Total
LERs
less
than
8
less
than
40
Continuous
Days Running
200
121 days (longest)
1
27
The
TRAP
committee
met
on
September
9,
1988,
and determined
that
Shearon
Harris
was
doing better
than
expectations
and
new plant
averages.
The inspectors
reviewed
the
LERs related
to maintenance
personnel
errors
from all- of 1987
through
September
1988.
In
1987
there
were
a total of 6
LERs related to maintenance
human performance
problems.
Human
performance
related
means
human
performance
was
a
contributing
factor - included
in
human
performance
errors
were
procedural
errors.
The total
1988
LERs-, to date,
related to mainte-
nance
human errors were two, with the last, one occurring in March.
A
Human
Performance
review was
conducted
for each
incident
+hat
was
human
performance
related.
This helped
reduce
the total plant
human
performance
related
LERs from 42 in 1987 to only
10 in 1988 through
September.
The Maintenance
Department
has also
formed
a crew to perform all
associated
with plant trips.
Before being
assigned
to the
crew
a
technician
must
have
had approximately
5 years
experience
and
had
satisfactorily
passed
the
School
to
be qualified to
24
work on the equipment.
This crew also
performed corrective mainte-
nance
on the equipment
on which it performed the
MSTs.
This concept
has.provided
posi.tive results,
with zero
personnel
error trips
due
to maintenance
MST crews
since
the
beginning
of plant life.
The
licensees
maintenance
training program
was accredited
by INPO which
was another positive step to reduce
personnel
error.
The
overall
positive results
of
reduction
and
maintenance
personnel
error reduction
were considered
to
be "a licensee
area
of
strength.
Post Maintenance'esting
"The inspectors
reviewed
the
licensee's
method for performing post
maintenance
testing.
MMM-019,
Post
Maintenance
Testing,
Rev.
0,
.provided
the
guidelines
for selecting
and
documenting
the
PNTR
following main'tenance activities
and outlined the responsibilities.
During the initial generation
of
a WR/JO,
the maintenance
planner/
analyst
reviewed the post-maintenance
test guide provided in MMM-OI9
and listed the
PMTR on the test
sheet
attached
to the WR/JO. If the
component
was in the ISI program,
the
WR/JO was next reviewed
by the
ISI Coordinator
who listed all
PMTR specified in procedure
ISI-203,
Inservice
Inspection
Program,
Rev.
5.
The
SF
then listed all
the
appropriate
operations
PMTR
on the test
sheet
during the pre-work
review of the
MR/JO.
The
SF was responsible
for assuring
that the
PMTR for
safety
related
equipment
and
Technical
Specifications
requi rements
were identified.
Upon, completion of the
PNTR,
the
SF
signed the test
sheet indicating satisfactory
results.
The
inspectors
reviewed
procedure
MMM-019 to verify that
adequate
administrative
work controls existed
to accomplish
post-maintenance
requirements.
The inspector also reviewed
numerous
MR/JOs to assess
the adequacy
of the
PNTR.
Planners
were interviewed to assess
their
knowledge
and abilities to determine
the
PNTR for various
MR/JOs.
No discrepancies
were
noted
in this
review of
PMTR
processing.
Overall,
the inspectors felt that the
licensee
had adequate
admini-
strative controls for identifying and conducting
PMTRs.
Preventive
and Predictive Maintenance
Programs
The instructions
and responsibilities for the development
and imple-
mentation
of the
PM program
were
contained
in procedure
MMM-003,
Preventive
Maintenance
Program,
Rev.
5.
The inspectors
reviewed this
procedure
and
conducted
interviews with- the
maintenance
manager,
maintenance
engineers
and planners
to assess
the
scope
and
adequacy
of the
licensee's
program.
The
equipment,
for inclusion
into
the
PM program
was
selected
from the
EDBS.
The
EDBS was modified
25
based
on
equipment
operating
performance,
cost
effectiveness
and
experience.
The criteria for including
a piece of equipment into the
PM program included:
Equipment affecting personnel
safety
Vendor
recommendations
Equipment specified in ANSI N18.7
Plant security equipment
Fire protection
equipment
Major equipment in the
Spare parts
Good maintenance
practices
When the piece of equipment
was included into the
PM program,
the
maintenance
staff determined
the frequency of the
tasks
based
on:
Regulatory
requirements;
vendor
recommendations;
experience
with
similar equipment;
and
engineering
analysis
of equipment
perform-
ances.
All
changes
to
the
EDBS
and
the
frequencies
were
controlled
by the
maintenance
staff,
using
the
feedback
report
as
delineated
in MMM-026, Maintenance
Feedback
Reports,
Rev. 0.
After the
PM procedure
or checklist is written, it was included in a
PM route.
The
PM routes
were stored in the
AMMS and were assigned
a
work request
number.
That work request
number could be used to track
the complete history of the
PM.
The maintenance
planner
issued
the
work requests
to the responsible
maintenance
foreman
who assigned
a
lead person for the
PM.
The
SF signed the work request prior to the maintenance
crew perform-
ing the
PM, indicating permission to commence
work.
Once the
PM was
completed,
the
maintenance
foreman
reviewed
the
work request
and
determined if the
PM should
be
rescheduled.
If the work request
could not
be
completed
or
was unsatisfactory,
the
foreman
routed
the
work request
to the
responsible
maintenance
supervisor.
The
maintenance
supervisor
ensured that followup corrective work requests
were
initiated to correct
discrepancies
found during
performance
of the
PM. If the
PM could not
be performed,
a justification was
provided
as to why it could not be run.
The appropriate
supervisor
approved
the justification
and
sent it to the
maintenance
manager
for review.
The completed
work requests
were sent to the planner
so
the data could be entered
into AMMS.
The
PMs not completed
were sent
back to the planner for rescheduling.
The licensee
performed
over
1800
PM routes
annually,
including
maintenance
surveillance
tests
(TS required)
and maintenance
periodic tests
(non..TS required).
At
the time of the inspection,
only 137
PMs were classified
as overdue.
The
PM program
had
adequate
administrative
controls for adding
new
equipment,
changing
PM frequency,
or
revising
PM procedures.
The
maintenance
department
was
observed
to
be adequately
following the
program
and providing effective preventive maintenance.
The
PDM program
was established
under
procedure
MMM-018, Predictive
Maintenance
Program,
Rev.
0.
This program
was still in the formative
stages
at the time of the inspections
The licensee"had,
in place,
a
comprehensive
vibration analysis
program which was established
under
PLP-607, Vibration Monitoring Analysis Program,
Rev.
0.
This program
covered
a total
of
311
safety
and
non-safety
related
pieces
of
equipment
included .in 16 routes.
The vibration readings
were trended
by maintenance
engineers
and
any
abnormal
readings
were brought to
the attention
of plant
management.
The licensee
had received
some
positive results
from this program - most notable
was the detection
of
a
problem with the
main
feed
pump
motor.
Other
PDM methods
described
in MNM-018 included:
Shock
Pulse Analysis, Oil Analysis,
Thermographic Analysis,
and Ultrasonic Testing.
The inspectors'oted
that the licensee
had
a program for lube oil testing
as delineated
in
CRC-218,
Lubrication Oil Testing,
Rev.
3.
This procedure
provided
instructions
for obtaining
lube oil samples
from the
RCPs,
diesel
fire pump engine,
turbine bearing
and
EDG.
However,
the
licensee
did not routinely sample other plant equipment
lube o'il for
trending
purposes.
The inspectors
also
noted that
programs did not
. exist for the other
PDM methods listed above.
The licensee
indicated
that these
programs
were irt the developmental
stages
and planned to
have
them in full implementation
by the
end of the next operating
cycle.
In response
to
on check valve degradation
and possible failures,
the
licensee
had
not yet established
a
program.
However,
the
licensee
planned
to have that program estab-
lished
by the end of the next operating cycle.
The licensee
was equipped with a
MOV diagnostic tester
MAC.
The
MAC
system
measured
the
maximum current of the motor,
which correlates
to the
amount of thrust.
At the time of the inspection,
the licensee
was
in the
process
of drafting
a
procedure
for
MAC testing,
and
diagnostic testing of MOVs was not routinely performed:
The licensee
did have
a procedure for troubleshooting
Limitorque valves.
MMM-024,
Limitorque Valve Failure Analysis
and Troubleshooting
Procedure,
Rev.
0,
provided
guidelines
and
requirements
fcr troubleshooting
and
determining root cause failures of Limitorque
MOV actuator failures.
The procedure
provided that the
foreman with the originating
MR/JO
determined
the applicability of this
procedure.
The
foreman
was
responsible
for documenting
the as-found conditions
and the detailed
sequence
of events to aid in determining root cause
~
The maintenance
engineers
were responsible
for providing technical. assistance
to the
foreman
and repair
team.
The effectiveness
of this program could not
be determined
due to the short
time it had
been
in place.
Discus-
sions with maintenance
personnel
indicated that the
foremen
had not
been
using this
process,
therefore,
the as-found details
have
not
been routinely documented.
.27
Overall,
the licensee's
PDM program was in its developmental
stages.
Licensee
management
has
stated
plans
and
schedules
for implementing
additional predictive maintenance activities.'he
lack of pr'edictive
maintenance,
other
than
vibration
analysis
and
TS
required oil
sampling,
was considered
an area of weakness.
This is identified as
inspector followup item (400/88-34-05).
Inservice Testing:'TOP
The inspectors
reviewed
procedure
ISI-203.
This procedure
contained
the
Section
XI testing
requirements
for
pumps
and
valves.
The
inspectors
noted
a discrepancy
concerning
the testing of the pressu-
rizer
The
PORVs were specified
by ISI-203 to be stroke tested
closed
with
a
maximum
stroke
time of '2.0
seconds.
The
licensee
tested
the
in
accordance
. with
OST
1805,
Pressurizer
Operability
18
Month Interval
Mode 5-6,
Rev.
2.
The
inspectors
questioned
why the
valves
were
not timed
in the
open direction.
,Although
no safety analysis credit
was taken for the
PORVs 'at power
operation,
they were required to provide overpressure
protection
(by
opening
on
demand)
during low-temperature
operation.
Shearon
Harris
utilized two out of the three
PORVs for the
LTOP System.
The
setpoints
were variable depending
upon
RCS temperature:
TEMPERATURE
F
LOM PORV psig
HIGH PORV psig
<100
125
250
300
335
390
400
400
425
440
400
410
410
435
450
The
LTOP was designed
to protect the
RCS from overpressure
when the
was limited to:
1) 'tart of an idle
RCP with secondary
side water temperature
less
than
50
F above
RCS cold leg temperature
or; 2)
the start of
a
CSIP
and its injection into
a water-solid
RCS.
The
PORV setpoints
were calculated
to maintain
the
RCS below
the
maximum allowable
system
pressure
set forth in
10CFR50 Appendix
G.
The
setpoint
calculations
assumed
a valve opening
time of 2.0
seconds
in determining the possible setpoint overshoot.
The inspec-
tors
nc ted if the actual
valve opening
times
were greater
than 2.0
seconds,
then the setpoint overshoot could be greater
than originally
calculated.
A significant
increase
in valve
opening
time could
result
in the
Appendix
G limits being
exceeded
during
a
design
bases
The
were
stroked
in the
open direction
when
the
licensee
performed-the
time to close test.
However, the time to open
was not
determined.
The
licensee's
evaluation
to determine
the appropriate
testing
of the
PORVs will be
followed
by the
inspectors
and
be
tracked
as
an Unresolved
Item (50-400/88-34-03).
28
PLP-401,
Ladder,
Scaffold,
and
Equipment
Use
and Storage,
Rev.
0,
was the procedure
used
to control
scaffolding throughout
the plant.
This procedure
stated in section
4. 1, Tagging:
"Ladders,
and portable
equipment
when in use
and
removed
from storage will be
tagged
to identify when it will be returned
to storage".
Further-
more,
section 5.5.2 states:
removed
from storage
areas
and erected
at
a particular work location will be tagged to specify
the responsible
person
and their
phone
number,
what the scaffolding
is being
used for, the date the scaffolding was erected,
and the date
it will be
returned
to storage".
Walkdowns
performed
in various
areas
of the plant
revealed
four examples
of scaffolding with no
identification tag at all in the auxiliary building,
and
17 examples
in the turbine building.
A tour made of these
areas with the Plant
Services
Supervisor indicated
no reason for this condition and action
was taken to immediately rectify it.
The inspector
reviewed
these
gA Surveillance
reports:
88-114 issued
August 25,
1988;88-115 issued
September
19,
1988;
and 88-129 issued
July
15,
1988.
All of these
reports identified problems in'he area
of scaffolding identification through
the
use of tags.
NCR 88-068
was
issued
against
the licensee
identified examples.
While the
21
examples
found by- the
inspectors
on 7/20/88
were indications of
a
failure to follow procedure, it was considered
that the licensee
had
identified the
problem
and
was still in the
process
of rectifying
the situation.
One of the
scaf folds identified
by the
NRC inspector
as not being
tagged
was
placed
over the
"B" MDAFW Pump.
The inspector
queried"
the
licensee
as
to whether
a safety
evaluation
was
performed
or
would be performed
on scaffolding erected
over safety related
equip-
ment before
a. mode
was entered
which would require the system to be
A review of the'pplicable
section of PLP-401 revealed
the
following statements:
Section
5;9.2.9
"When scaffolds
are
to
be
erected
in areas
other
than 5.9.8.2
where if the scaffold were to
collapse
or fall could
damage
nuclear safety-related
components
or
components
critical
to
continued
Unit operation,
the
following
provisions must be adhered
to in addition to all
OSHA and applicable
safety standards".
Sections
5.9.2.9.a
and
b describe
the construc-
tion of the scaffold, but Section 5.9.2.9.c
states:
"Scaffold may be
left in place for up to
6 weeks without an engineering
evaluation.
Scaffold which is left in place longer than
6 weeks
should receive
an
engineering
evaluation for its structural
integrity".= This is the
only place
in PLP-401 that
recommends
an engineering
evaluation for
scaffolding over and around safety related
equipment.
It allows the
scaffolding to
be in place for up to
6 weeks before the evaluation,
and then only addresses
the structural'oncerns
and not the potential
operability
concerns
for
redundancy
single
failure criteria
and
seismic
requirements.
29
The licensee
was
made
aware of the inspector's
concerns
in this area
and
subsequently
revised
PLP-401
on October
14,
1988 making adequate
reference to'the
above
noted concerns with the following statement:
Section
5.9.3.8.a.:
"Scaffolds shall
be carefully planned
and
coordinated
with the SF, designee
to ensure
where possible that
scaffolds are not erected
simultaneously directly over redundant
pumps/components
in a system
and to ensure
by reasonable
visual
checks
that
the
wi 1.l
not
cause
a
loss
of both
trains
solely
due to scaffolding if it should fail.
The
SF,
designee
shall
have final jurisdiction as to final placement
of
The licensees
efforts to correct the lack of scaffold, tagging
and
the
subsequent
revision of PLP-401 satisfy
the inspectors
concerns
in this area.
No additional
violations or deviations
were
noted
except
as
noted
in
paragraph
4.d.
5.
Management
Controls
The subject
of plant
management
controls
was reviewed in order to assess
the adequacy of the following areas:,
Management
assertiveness
and control
Coordination of activities between plant groups
Accuracy
of plant
status
information
conveyed
in plant
status
meetings
versus actual plant status
Participation
by .attendees
in plant status
meetings
Adequacy of LERs and threshold for initiation
Interface
between plant groups
Resoluticn of previous
problem areas.
Time
spent
by the
plant
manager
reviewing
the
status
of various
plant areas
such
as operations,
maintenance,
training, engineering,
and plant housekeeping.
The
organizational
structure
was
reviewed
to
determine
that it was
prescribed
by corporate policy documents
and standards;
that its functions
were adequately
defined
by administrative
procedures;
and,
that staffing
and staffing plans fulfilled the chartered
roles.
30
The
status 'of
implementation
of major
organizational
functions
was
'determined
by review of procedures,
review of records,
interviews
and
discussions
with
licensee
managers,
supervisors
and
staff
personnel
inside
and outside the departments
of interest.
'a
~
Plant Nuclear Safety
Committee
The activities of the onsite safety review committee,
the
PNSC-,
were
reviewed to determine if the
committee
was functioning
as required
by the
TS,- was
providing
adequate
interface
with various
plant
disciplines,
and was performing adequate
safety evaluations.
In addition
to the
requirements
delineated
in the
TS,
the
PNSC
activities
are
controlled
by administrative
procedure
AP-013.-
To
review
the
committee's
activities
the
inspector
reviewed
the
following PNSC documentation:
AP-013, Plant Nuclear Safety Committee,
Rev.
3
AP-011, Safety Reviews,
Rev.
2
AP-014, Criteria
For gualified Safety Reviewers,
Rev.
6
AP-006, Procedure
Review And Approval,
Rev.
8
Selected
meeting minutes
The inspector
also
attended
PNSC meetings,
interviewed members,
and
alternate
members.
The
PNSC
holds
meetings
usually
every
Thursday.
More
frequent
meetings
or
special
meetings
are
held
as
needed.
There
is
good
member
participation
during
the
meetings
and
evidence
of strong
management
controls
The committee
encourages
outside participation.
This
was
evidenced
by
the
presentation
by individuals
who
were
responsible
for initiating changes,
LERs,
and engineering
data.
The
individuals
were
required
to
make
presentations
to
and
answer
questions
from the
PNSC.
The
PNSC
appear s to
be accomplishing their assigned
functions.
The
use
of outside
individuals
for presentations
and
information is
considered
an effective enhancement.
i
31
Plant Status
Meetings
Selected
plant
status
meetings
were
attended
to determine
whether
day-to-day
plant
activities
and
outage
activities
were
being
adequately
disseminated
to the
applicable
plant staff,
to verify
the
accuracy
of status
information,
to monitor participation
by
attendees
and
management
assertiveness
and control.
The licensee's
daily plant status
meetings
consisted
of the following:
6:30 a.m.
Refueling Outage Meeting
8:30 a.m.
Morning Coordination Meeting
6:30 p.m.
Refueling Outage
Meeting
An effective interface
was observed
between plant groups in addition
to participation
by
personnel
in all
the
plant
meetings.
The
various
status
meetings
provided
a discussion
of plant conditions,
critical,path
items for recovery
from the outage,
changes
expected
to occur during the next twelve hours,
scheduling,
and coordination
of activities.
There is
good
management
attendance
and control at
the meetings
and adequate
multi-discipline attendance.
The
Plant
General
Manager,
Operations
conducts
at least
one daily
tour of the plant including the turbine building, the control
room
and
the
RAB.
This tour is normally conducted
in the morning, before
the 8:30 meeting.
Parameters,
selected
by the manager,
are
recorded
as well
as
log reviews
conducted
during the tour.
Plant
personnel
are interviewed during the tour as to what
has
happened
recently in
their
areas.
This tour and review give the manager
a good base for
discussion
of plant status
at the meeting.
The Site
Vice President
conducts
a tour at least
weekly in the
same
areas.
On Thursday of
each
week,
an area of the plant is selected
for inspection
by the
Plant
General
Manager,
Operations
and
his
Unit Managers.
The
deficiencies
noted during this inspection
are tracked until they are
resolved.
The
Plant
General
Manager
also
has
reported
to
him
weekly, the number of entries
each
supervisor
on the site
makes into
the Control
Room and
RAB.
The licensee
was observed to be :onducting effective and disciplined
management
meetings
to transfer
information
and control activities.
Management
appeared
to be intimately invnlved in daily activities.
The Plant
General
Manager,
Operations
indicated that
a Duty Manager
program
has
been
initiated for weekend
coverage
for response
to
plant incidents
and problems.
Operating
Experience
Review
The
licensee's
program for reviewing
and
disseminating
operating
experience
feedback
was
reviewed
during
the
inspection.
ONSI-I
Operating
Experience
Feedback,
Rev.
5;
AP-609,
Reviewing
Of
incoming
NRC/INPO
Correspondence,
Rev.
l;
AP-031,
Operational
Experience
Feedback,
Rev.
1 are
the controlling procedures
for the
32
review
and
promulgation
of operational
experience.
The following
/ documents
are
screened
by
ONS for
. operating
experience
feedback:
Operating
Experience
Reports for site
events;
NSSS/Yendor Service
.Bulletins;
Documents
from other
Company
ONS Units and the
NSR Unit;
INPO -SOERs
and
SERs;
NRC
IE Notices;
and
other
industry
sources
deemed
appropriate
by the Director-ONS.
A weekly meeting is normally
held during
periods.
when
the
plant
is
operating.
This
meeting
consisted
of members
of the
ONS staff and the Unit Managers
as well
as training staff.
Due to the
outage
in progress
this meeting
was
suspended
and the
ONS staff
commenced
the
issuance
of an operating
experience
feedback
reminder bulletin.
These
bulletins
summarized
information received from'arious
sources
which was related
to the
outage activities
and the
subsequent
startup
and
appeared
to
be
a
very effective method of promulgating important information.-
'd.
Quality Assurance
The inspector
reviewed the requirements
of TS 6.5.4
on the
scope
and
frequency of audits in conjunction with the audit planning
schedule.
The
planning
matrix contained
all of the
TS
requirements.
Audit
checklists
and completed
audits
were
selected
for review of audit
depth
and
scope,
management
response
to findings,
timeliness
of
correction action,
and methods
used to expedite, overdue
responses.
A
review of the on-site Quality Control activities
was conducted.
The
surveillance
schedule
was
reviewed to determine
the
percentage
of
completion
of
scheduled
survei llances.
For
1988,
including
the
first'efueling outage,
the completion percentage
of scheduled
audits
was
77%.
A
QC auditor
has recently completed
the licensed operator
training classes
and
was
seen
to
be
a positive factor in improving
the technical
accuracy of QC surveillance
in the operations
area.
A
new
QC initiative to verify system
alignment
and major flow paths
and drawings
has
been initiated.
This is also
seen
as
a positive
enhancement
and further example of managements
commitment to quality.
e.
Performance
Monitoring Programs
The
inspector
reviewed
the
Plant
Performance
Indicator Charts
and
interviewed selected
management
personnel
to determine
the parameters,
or indicators monitored,
goals in each area,
and the communication of
performance
goals within the organization.
The performance
indicator
charts
included:
Equi valent Avai 1 abi 1 ity
Safety
System Availability
Net Heat Rate
Radiation
Exposure
Radwaste
Shipments
Surface
Contamination
Area
Unplanned Safety
System Actuation
Personnel
Error
LER
Site Employees
- 0&M Production
Expense
- 0&M Budget Expenditures
'
Capital
Budget Expenditures
Forced
Outage
Rate
Unplanned
Reactor
33
-
No Lost Time Personnel
Injury
Vehicle Accident Rate
- Plant
Change
Requests
Open
- PCRs
By Organization
- Equipment Drains Inleakage
- Lost Time Personnel
Injury
- Megawatt Hours (Net)
-
PCRs With One Exception
- Floor Drain Inleakage
Charts
of
these
performance
indicators
are
positioned
in
many
locations
throughout
the plant
and
administrative
and
maintenance
offices.
These
charts
permit ready
comparison
between
established
goals
and actual
performance.
No violations or deviations
were noted.
6.
Exit Interview (30703)
The
inspection
scope
and
findings
were
summarized
on October
7,
1988,
with
those
.persons
indicated
in
paragraph
I
above.
The
i.nspectors
described
the
areas
inspected
and
discussed
in detail
the
inspection
results listed below.
Proprietary
information is not contairied in this
report.
Dissenting
comments
were not received
from the, licensee.
Item number
Status
Descri tion/Reference
Para
ra
h
400/88"34-01
OPEN
VIOLATION - Failure to document
that
monthly caution
tag
audits
had
been
conducted
between
the
dates
of
5/29/88
and
8/31/88,
(paragraph 2.b.).
400/88-34"02,
400/88-34-03
400/88-34-04
OPEN
OPEN
OPEN
VIOLATION - Fa.ilure to obtain
author ization
from
the
Plant
Manager for maintenance
personnel
to exceed
TS overtime guidelines,
(paragraph 4.d.)
~
UNR - -The licensee's
evaluation
results
. to
determine
the
appropriate
testing
of the
for LTOP will be reviewed,
(paragraph
4.m.).
IFI - The licensee will develop
a
plan
to reduce
the
large
backlog
of
overdue
procedure
revisions,
(paragraph 4.g.).
34
400/SS-34-05
OPEN
IFI - Plans
and schedules
for
implementing, additional
predictive maintenance activities
will be developed,
(paragraph
4.1.).
AMM - Administrative Management
Manual
AMMS Automated Maintenance
Management
System
ANSI - American National Standards
Institute
AO Auxi1-iary Operator
AP - Admin'istrative Procedure
ASME - 'American Society of Mechanical
Engineers
8/RFIR Breakdown/Repetitive
Fai lure Investigative
Report
CFR - Code of Federal
Regulations
CHF Computerized History File
CM - Corrective Maintenance
CSIP - Charging/Safety
Injection'ump
CVCS - Chemical
and Volume Control
System
EDBS
Equipment
Data
Base
System
EDG Emergency
Diesel Generator
EOP - Emergency Operating
Procedure
EQ - Envii onmental Qualification
ESF - Engineered
Safety Features
ESFAS - Engineered
Safety Features
Actuation System
FBR - Feedback
Report
FSAR - Final Safety Analysis Report
HVAC - Heating Ventilation/Air Conditioning
INPO Institute of Nuclear
Power Operations
IPBS - Integrated'Planning
Budget
InService Inspection
IST InService Testing
LCO - Limiting Condition for Operation
LER Licensee
Event Report
Low Temperature
Overpressure
Protection
MAC Motorized Actuator Characterizer
MDAFW Motor Driven Auxiliary Feedwater
MFBR - Maintenance
Feedback
Report
MMM Maintenance
Management
Manual
MOV Motor Operated
Valve
MST Maintenance
Surveillance
Test
MWR - Maintenance
Work Request
NCR Non-Conformance
Report
NPRDS - Nuclear Plant Reliability Data
Base
System
NRC - Nuclear Regulatory
Commission
35
NSR -
Nuclear Safety
Review
NSSS - Nuclear
Steam Supply System
OMM - Operations
Management
Manual
ONSI - Onsite Nuclear Safety Instruction
OP
Operating
Procedure
OPA Operational
Performance
Assessment
OSHA -. Occupational
Safety
and Health Administration
OST - Operations
Surveillance Test
Plant
Change
Request
PDM - Predictive Maintenance
PGO - Plant General
Order
PID Project Identification
PLP
Plant Programs
PM - Preventive
Maintenance
PMT - Post Maintenance
Test
PMTR Post Maintenance
Test Requirement
PNSC - Plant Nuclear Safety Committee
'ORV - Power Operated Relief Valve
PT - Performance
Test
QA - Quality Assurance
QC - Quality Control
RAB Reactor Auxiliary Building
Reactor
Coolant
Pump
System
RHR Residual
Heat
Removal
RO - Reactor Operator
SALP - Systematic
Assessment
of Licensee
Performance
SCO - Shift Control Operator
SER - Safety Evaluation Report
SF - Shift Fo~eman
Tube Rupture
SOER - Significant Operating
Experience
Report
SOOR - Significant Operational
Occurrence
Report
SRO - Senior Reactor Operator
SS - Shift Supervisor
TS - Technical Specification
WR - Work Request
WR/JO
Work Request/Job
Order
ATTACHMENT
EXAMPLE WORK HOURS
Sat
Sun
Mon
Tue
Wed
Thu
Fri
Total
Week
1
. Week
2
0.0
8.0
10.5
11.0
13.5
12.0
12.5
67.5
12.0
12.0
10.0
12.0
12.0
12.0
8.0
78.0
Notes:
2.
During week 2, the
78 total hours worked exceeded
the
TS guide-
line of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any
7 days.
This 78-hours
in 7 days
was
approved
by the plant manager retroactively after the excessive
hours were identified by the inspector.
During the
7 consecutive
days starting
Wednesday
of week
1 and
ending with Tuesday of week 2,
a total of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />
was worked.
This was
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> more,
in
a
7 day period, than'he
78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />
approved
by the plant manager.
3.
During week 1,
on Wednesday
and Thursday;
the 25.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> worked
exceeded
the
TS guideline of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
This
was not approved
by the plant manager.