ML18054A501
| ML18054A501 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/18/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A500 | List: |
| References | |
| 50-255-88-20, NUDOCS 8901240363 | |
| Download: ML18054A501 (49) | |
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NOTICE OF VIOLATION Consumers Power Company Docket No. *50-255 License No. DPR-20 Palisades Nuclear Generating Plant As a result of the inspection conducted on September 19-23, October 11-14, and 20, 1988, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1988), the following violations were identified:
- 1.
10 CFR 50, Appendix B, Criterion V, as implemented by Consumers Power Company Quality Assurance Program, Section 5, requires that activities be prescribed by procedures or drawings appropriate to the circumstances, and accomplished in accordance with those procedures or drawings.
Contrary to the above:
- a.
A safety evaluation check of Temporary Modification 88-052 for 10 CFR 50. 59 app.l i cabi l i ty was not performed as required by Procedure 3.07, 11Safety Evaluation,i 1 Revision 1, Attachment 1.
(255/88020-0lA)
- b.
Various termination points in Diesel/Generator Excitation Panel C-22 had three terminal lugs secured by holding nuts that lacked full thread engagement, and engineering approvals had not been obtained as required by Procedure MSE-E-12, 11Cable Terminations, 11 Revision 2.
This condition existed for an indeterminate length of time.
(255/88020-018)
- c.
Required procedures specified by Work Order 24802607 were not in the work package or at the Diesel/Generator Panel G-12 work location as required by Procedure 5.01, 11 Processing Work Requests/Work Orders, 11 Revision 8, Attachment 5.
(255/88020-0lC)
- d.
Work steps 5.2.2.2, 5.2.4.1, and 5.2.5 of Procedure I-FC-627-02-001, 11 Installation of Diesel Generator 1-1 Contactors and Annunciator, 11 Revision 0, were not signed off when the work was accomplished as required by Procedure 5.01, 11 Processing Work Requests/Work Orders, 11 Revision 8, Attachment 5.
(255/88020-0lD)
- e.
As observed by the inspector, no authorization was obtained to perform work out of sequence as required by Procedure I-FC-627-02-001, 11 Installation of Diesel Generator 1-1 Contactors and Annunciator, 11 Revision 0), Step 5.
(255/880202-0lE)
- f.
All prerequisites to performance of work, and work steps for completion of work were not accomplished as required by the procedures referenced in Work Order 24803875, 11 E-54-A CCW Heat Exchanger Inspection.
11 (255/88020-0lF)
This is a Severity Level IV violation (Supplement 1).
- 2.
10 CFR, Appendix B, Criterion VI, as implemented by Consumers Power Quality Assuranc.e Program, Section 6, requires in part that measures be established to control the issuance of drawings, including changes thereto, and that these measures shall assure that drawings, including changes, are distributed to and used at the location where the prescribed activity is performed.
Contrary to the above, the licensee failed to establish measures to inform the document control center about changes to drawings caused by modifications' to hardware.
As a result, the inspectors observed that work on diesel/generator Panel G21 was accomplished in accordance with the incorrect revision of Drawing 950W48Ml2, Sheet 96.
(255/88020-04)
This is a Severity Level IV violation (Supplement 1).
- 3.
10 CFR 50, Appendix B, Criterion XVI, as implemented by Palisades Quality Assurance Program, Section 16, requires that conditions adverse to quality be promptly identified and corrected, and action be taken to preclude repetition.
Contrary to the above:
- a.
As of October 20, 1988, the licensee failed to correct and resolve discrepancies with approximately 300 electrical drawings identified in early 1988 by Configuration Control Project during electrical plant walkdown inspections.
(255/88020-06A)
- b.
The licensee failed to take prompt corrective action to resolve a wiring discrepancy in Diesel Generator Panel G-31 identified in March 1988 that resulted in bypassing the lubrication oil heater flow switch of Diesel/Generator 1-2 for eight months; a deviation report was not initiated by the licensee until October 12, 1988.
(255/88020-068)
This is a Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation:
(1) the corrective actions that have been taken and the results achieved; (2) the corrective actions that will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
i-1~-W Dated
EXECUTIVE
SUMMARY
An announced NRC team inspection of maintenance was conducted at the Palisades Nuclear Generating Plant during the period of September 19-23, and October 11-14, and 20, 1988.
The inspection was conducted to evaluate the extent that a maintenance program had be~n established and implemented at Palisades to assure the preservation or restoration of the availability and reliability of plant structures, systems, and components to operate on demand.
Three major areas were assessed including overall plant performance as affected by maintenance, management support of maintenance, and maintenance implementation.
To accomplish this task, several maintenance related activities were evaluated to determine if maintenance was accomplished, effective, and self-assessed.
The following are the significant strengths and weaknesses.
STRENGTHS The inspection team noted specific strengths related to:
work backlog control, work prioritization, valve improvement program, electrical maintenance facilities, Radiological Protection support, experience and background of QA personnel, control of measuring and test equipment, and rework monitoring.
WEAKNESSES The inspection team noted specific weaknesses related to:
timeliness of corrective action for deficiencies identified by the Configuration Control Project, lack of measures to control changes to drawings with hardware modifications in progress and a system to ensure work is accomplished using the correct revision of drawings, missing maintenance histories and trend analysis for electrical components, failure to follow maintenance work order instructions and procedures, no formally documented program or goals for
. integration of PRA into the maintenance process, and lack of QC involvement and participation in maintenance work activities.
The inspection team 1 s findings tended to validate those identified by the licensee during the INPO self-assessment of maintenance.
However, there was some concern with licensee action to correct some of the findings.
For example, adherence to and adequacy of work instructions and contractor controls, where future permanent corrective action was planned, interim actions had not been totally effective and the problems were recurring.
Although these weaknesses were identified, none appeared to affect plant system operability.
CONCLUSION Results of this inspection showed overall satisfactory performance in the establishment and implementation of an effective plant maintenance process by the licensee of the Palisades Nuclear Generating Plant.
Based on the review of past work activities, observations of ongoing work activities, work controls, and attempts at self assessment the inspectors determined that overall, electrical, mechanical, and I&C maintenance and support activities were adequately performed to maintain operability of components at a level commensurate with the components 1 function.
However, some of the activities identified above were in violation of regulatory requirements as noted.
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3.1 3.2 3.3 3.3.1 3.3.2
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,.,) *
._I 3.3.4 3.3.5 3.4 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.5 3.6 3.7 3.8 3.9
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- 6.
CONTENTS Persons Con.tacted Licensee Action on Previous Inspection Findings Introduction to the Evaluation and Assessment of Maintenance Historic Data.
Description of Maintenance Philosophy Review and Evaluation of Maintenance Accomplished Backlog Assessment and Evaluation.
Review and Evaluation of Completed Maintenance Engineering Support Work Control Personnel Control Observation of Current Plant Conditions and Ongoing Work Observation of Material Condition Observation of Ongoing Work.
Radiation Protection Support of Maintenance Maintenance Facilities, and Control of Measuring and Test Equipment Configuration Control Project Licensee's Assessment of Maintenance (Quality Verification)
Overall Plant Performance as Affected by Maintenance Management Support of Maintenance Maintenance Implementation Conclusion Open Items Unresolved Items Exit Meeting 3
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9 18 18 19 21 21 26 34 36 36 39 40 40 42 43 43 43 43
U.S. NUCLEAR REGULATORY COMMISSION REGION I II Report No. 50-255/88020(DRS)
Docket No. 50-255 License No. DPR-20 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Covert, Michigan Inspection Conducted:
September 19-23, October 11-14, l )
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S. *A. ~eynolds, Team eader Inspectors:
- 1
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N. C. --Choules t;. )~CJLfvi Z. FaleCts 1.1- ~~~r -L..
'i rt. CJVv' o*-
M. 'A. KHnowsk1
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P.R. Rescheske Contractors: t.*j )~cJ[* k B. L. to 11 ins, INEL/(GG Idaho t*}* )~l1,1()(* k_
J. L. ~ansen, INELtflEGG Idaho and 20, 1988 1 ~I Date 1 5 i Date
/ f 7 Date
/- 10-- 8 7 Date 1/;0/17 Date 1/;oft/
Date 1 8 '1 Date
/-ro - o 1 Date
Approved By:
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i-18-61 F. J. Jab-lonski, Chief Maintenance and Outage Section Date Inspection Summary Inspection on Settember 19-23, October 11-14, and 20, 1988 (Report No. 50-255/88020 DRS))
Areas Inspected:
Special announced team inspection of maintenance, support of maintenance, and related management activities.
The inspection was conducted by utilizing Temporary Instruction 2515/97, the attached Maintenance Inspection Tree, and selected portions of Inspection Modules 40500, 62700, 62702, 62704, 62705, and 92701 to ascertain whether maintenance was effectively accomplished and assessed by the licensee.
Results:
Overall, implementation of the licensee's maintenance program was determined to be satisfactory.
Areas of strengths and weaknesses were identified as discussed in the executive summary.
Three violations were identified:
failure to follow proc~dures in several areas, failure to control drawing changes, and failure to take prompt corrective action for identified discrepancies.
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DETAILS Persons Contacted Consumers Power Company
- D. P. Hoffman, Vice President, Nuclear Operations
- G. P. Slade, General Manager, Palisades Plant
- J. D. Alderink, Staff Engineer R. M. Brzenski, Instrum~nt & Control Engineering and Support Superintendent
- R. B. Kasper, Electrical Maintenance Superintendent
- R. E. McCaleb, Quality Assurance Director
- R. D. Orosz, Engineering and Maintenance Superintendent
- T. J. Palmisano, Systems Engineering Superintendent
- J. P. Pomaranski, Project Site Manager U.S. Nuclear Regulatory Commission (USNRC)
- H. J. Miller, Director, Division of Reactor Safety (DRS)
- ~. L. Forney, Deputy Director, Division of Reactor Projects (DRP)
- \\~. L. Axelson, Chief, DRP Branch 2
- B. L. Burgess, Chief, DRP, Section 2A
"'J. J. Harrison, Chief, DRS, Engineering Branch
- F. J. Jablonski, Chief, DRS, Maintenance and Outage Section
- E. R. Swanson, Senior Resident Inspector
- Indic~tes those attending the exit meeting at Palisades Plant on October 20, 1988.
Other licensee personnel were contacted as a matter of routine during the inspection.
- 2.
Licensee Action on Previous Inspection Findings 2.1 (Closed) Open Item (255/85011-02) and (255/86035-98):
Replace liquid radwaste effluent monitor, RIA-1049, and ensure operability of new system.
A new monitor was installed with a full-flow monitor with 4 pi shielding.
The system was operational.
These items are closed.
2.2 (Closed) Open Item (255/86035-63):
Permanently shield the shutdown heat exchangers and remove existing hot spots.
Flushing of the 2.3 drain lines for the heat exchangers was successful in removing a.
900 R/hr hot spot and other hot spots.
Because of the success of the flush, the licensee decided not to permanently shield the heat exchangers.
Currently, the highest reading hot spot is approximately 2 R/hr, and the general area readings around the heat exchangers range from 3-50 mR/hr.
This item is closed.
(Open) Open Item (255/86035-96):
Perform Q-list interpretation regarding the sample pumps, P-1810 and P-1811, associated with 3
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2.6 RIA-1810 and RIA-1811, East and West Safeguards Rooms ventilation monitors.
A Q-list interpretation of the pumps was conducted on May 18, 1987, and resulted in the pumps not being Q-listed.
- However, a discussion with the RIA system engineer indicated that this interpretation was incorrect, because the pumps were necessary for the monitors to perform the intended function, that is, generate an isolation signal after a LOCA to close ventilation exhaust dampers in the East and West Safeguards Rooms if radioactive exhaust from these rooms exceeded permissible limits.
The system engineer stated that the interpretation would be re-performed.
This issue will be reviewed-again during a future inspection.
(Closed) Open Item (255/86035-97):
Replace the off-gas radiation monitor, RIA-0631.
A new inline monitor was installed.
The monitor was operational and according to licensee representatives, had greater sensitivity to detect primary-to-secondary leakage than the previous monitor (see Inspection Report No. 50-255/88017(DRP) for additional discussion on detecting primary-to-secondary leakage).
This item is closed.
(Open) Open Item (255/86035-99):
Perform a Q-list interpretation on the controlled lab monitor, RIA-2304.
Licensee records indicated an interpretation was performed on August 15, 1988, and resulted in the monitor not being included on the Q-list.
The Q-list interpretation of this monitor will be reviewed during a future inspection.
(Open) Open Item (255/86035-116):
NRC followup of Item No. 318 (SWS-01) identified by the licensee 1s 1986 Material Condition Task Force (MCTF) effort.
The actions resulting from this effort were generally equipment related improvements or evaluations intended to enhance plant performance and reliability.
The open item tracked a portion of Item No. 318 (SWS-01), specifically the inspection, cleaning, and rebuilding as necessary, of all Service Water System (SWS) valves manufactured by Allis Chalmers.
The original commitment scheduled completion of this item for the 1988 Refueling Outage.
However, a letter dated July 29, 1988, to the NRC from Consumers Power, updated the completion status for this item by deferring the inspection of the remaining valves into the Palisades Five Year Plan.
According to the licensee, the basis for the deferment was that the remaining valves were not easily accessible and/or that inspection could not be performed without isolating the entire SWS.
Budget constraints and provisions for establishing an alternate shutdown cooling system were also stated as contributing factors to the deferment.
Establishing alternate shutdown cooling only for valve inspection was not considered beneficial by the licensee, and no immediate concerns with the valves were noted.
The inspector noted that inspections had been completed by the licensee on a number of the accessible valves, and documented in work order packages.
This open item will remain open pending completion by the licensee, and review by the NRC.
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2.7 (Open) Open Item (255/86035-118):
Commitment for evaluating sources of SWS vibration using signature analysis.
An engineering analysis 2.8 2.9 had been performed by a consultant contracted by the licensee to determine the source of the vibrations and to develop a recommended solution for the problem.
This item remains open because the licensee had not fully evaluated the results of the analysis nor established a methodology for implementing a solution.
A solution for the vibrations is targeted for completion in calendar year 1989.
(Closed) Open Item (255/87027-05):
Preventive Maintenance (PM) requirements were not adequately addressed in Facility Change FC-725.
The minor facility change replaced the original Copes-Vulcan valves, atmospheric dump valves, with Masoneilan valv~s. The concern was that no objective evidence was found in the FC package which indicated that the PM requirements were reviewed and revised to reflect the requirements of the new valves.
Administrative Procedure No. 903 was used by the licensee to document the FC and provide design checklists and review requirements.
This procedure was subsequently revised and the checklists were improved.
For example, rather than checking the applicability (yes/no) of an activity/process, the revised design document checklist required that the applicability be based on whether it is a reference only or a revision is required.
This will identify when a maintenance procedure is required to be revised.
The design review, design input, and package document checklists also provided checks on activities/processes to be completed, and objective evidence of completion.
The licensee documented the requirements and completion of the PMs for the.
Masoneilan valves in Action Item Report (AIR) No. A-PAL-88-014 and A-PAL-88-007.
Based on the inspector 1s review of the administrative procedure and the PMs, and discussions with the licensee, this item is closed.
(Closed) Unresolved Item (255/87027-10):
Improper control room logbook entries.
The licensee evaluated the inspector concern in AIR No. A-PAL-88-012.
Plant Administrative Procedure No. 4.01, 11Shift Operations, 11 Revision 8, Section 5.7, addressed shift records.
This procedure was subsequently deleted; the requirements of Section 5. 7 were revised and appear in Procedure No. 4.00, 110perations Organization, Responsibility, and Conduct, 11 Revision 6.
The revision clarified the requirements for log entries in the Shift Supervisor Logbook, Control Room Logbook, Reactor Logbook, and Auxiliary Operator Logbooks.
This was accomplished by reducing duplication of entries to more appropriately meet the needs of Operations and provide a base of minimum required entries.
Specifically, the responsibilities for entries, such as, performance of surveillance testing was clearly delineated.
Major equipment status entries remained the responsibility of both the Shift Supervisor and Control Room.
Removal and returning equipment to service was required to be documented in the Control Room Log.
Based on the inspectors review of the revised procedures and the actions documented in the AIR, this item is closed.
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v' I) 2.lC (Closed) Open Item (255/87027-11):
Operator awareness in identifying system/components status.
The licensee evaluated the inspector concern and the methods available as aids to the operators, and documented the results in AIR No. A-PAL-88-006.
The existing tools available to the operators were considered sufficient to maintain accurate knowledge of equipment status, when understood and properly used.
Training and meetings were conducted with the licensed operators to discuss Administrative Procedure No. 4.02, 11Control of Equipment Status," emphasize individual responsibilities, and communicate supervisor expectations.
Based on the licensee 1s effort to enhance operator awareness of plant status, this item is closed.
- 3.
Introduction to the Evaluation and Assessment of Maintenance 3.1 This inspection was conducted to.evaluate the extent that a maintenance program had been developed and implemented by the licensee of the Palisades Nuclear Generating Plant.
Three major areas were evaluated:
(1) overall plant performance as affected by maintenance; (2) management support of maintenance; and (3) maintenance implementation.
The goals of this inspection were to evaluate maintenance activities to determine if maintenance was accomplished, effective, and assessed by the licensee to assure the preservation or restoration of the availability and reliability of plant structures, systems, and components to operate on demand.
Inspection data were obtained by review of work already accomplished, by observation of current plant conditions and work in progress, and by evaluation of the licensee 1s attempt at self assessment of maintenance and correction of any weaknesses.
Major areas of interest included maintenance associated with electrical, mechanical, instrument and control, and the support areas of radiological controls, engineering, and quality control.
Problems identified by the NRC inspectors were evaluated for effect on Technical Specification operability and technological or managerial weakness.
This inspection was based on the guidance provided in NRC Temporary Instruction 2515/97, 11Maintenance Inspection, 11 and drawing 425767-C, 11Maintenance Inspection Tree.
11 The drawing, which is attached to this report, was used as a visual aid during the exit meeting.
Historic Data The inspectors prepared for this inspection by review of data that described the Palisades operating history in terms of availability, operability, reliability, and radiation exposure.
Included were Licensee Event Reports (LERs), the latest SALP report, other NRC inspection reports, and PRA insights.
Primarily, the inspectors
. were sensitive to those technical and managerial problems that appeared to be maintenance related.
Results of the review indicated the following:
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Licensee had known problems and was taking corrective actions to festore the original design margin of the Service Water System.
The forced outage rate, which is the percentage of time planned for electrical generation that the unit was unavail~ble due to forced events, had improved over several SALP periods to approximately 30%; however, this was still an NRC concern.
One of the four LERs attributed to maintenance in the previous SALP period involved the low pressure safety injection (LPSI) pumps; the other three LERs were caused by maintenance personnel errors.
In addition, there were recurring problems with radiation monitors due to age, and problems with control of contractors.
Based on the review, the inspectors selected the Service Water System, the lbw pressure safety injection portion of the Engineering Safeguards System, and the Radiation Monitoring System as subjects foi~ further review, which are discussed throughout this report.
3.2 Description of Maintenance Philosophy 3.3 3.3.l The inspectors reviewed policy statements, administrative procedures, and organization charts, which indicated that the licensee had developed a plan for maintenance, including the facilities, personnel, and procedures to affect satisfactory maintenance.
Discussions by the inspector with selected ma~agers, engineers, and workmen indicated that those personnel were knowledgeable and aware of the established goals and performance objectives.
Licensee management was committed to improve maintenance at Palisades and was in the second year of the five year plan that had been developed by the licensee.
The scope, depth, and breadth of the preventive maintenance program has steadily changed and improved.
Review and Evaluation of Maintenance Accomplished Backlog Assessment and Evaluation The inspectors reviewed the amount of work accomplished as compared to the amount of work scheduled.
The area of interest was that work which could affect the operability of safety-related equipment or equipment considered important to safety, such as some balance of plant components.
Maintenance work item backlogs were evaluated for safety impact of deferrals, and causes such as lack of personnel, lack of parts or engineering support.
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3.3.1.1 Review of Corrective Maintenance Backlog 3.3.1.2 There was a backlog of approximately 280 corrective maintenance work orders (CMWOs) that were scheduled to be performed after the current 1988 refueling outage.
This backlog appeared to be about a three month work load based on the work order completion rate prior to the current outage.
Operations planners reviewed all work orders to prioritize the work and determine when the work should be performed.
It appeared that these determinations were technically oriented in that priority was based on operability and safety in lieu of schedule.
The CMWO backlog was assessed to determine the number of WOs and the impact on operability and safety.
Based on a priority system of 1-8, only two of the WOs had high priority, Priority 7.
One CMWO was awaiting procedure or engineering review and the other was recently identified and available for scheduling.
Over 67%
of the work orders had a priority of 6.
A review of several of those WOs indicated that there was no adverse impact on operability or safety.
Approximately 15~~ of the total WO backlog was.awaiting procedures or engineering review, 15% were awaiting parts or tools, 16% were in planning or on hold by planning, and approximately 46% were available for scheduling or scheduled for a future outage.
As discussed elsewhere in this report, it was noted during a review of WOs for electrical maintenance that there may be a potential weakness in too liberal interpretation of categorizing work for inoperable equipment during outages as routine 11outage 11 work in lieu of CM.
It was also noted that on at least two other occasions maintenance activities were incorrectly classified CM when PM was appropriate and vice-versa.
In addition, lack of root cause analysis to affect corrective action contributed to recurring CMWOs in the electrical and I&C areas.
Review of Preventive Maintenance Backlog The preventive maintenance (PM) program was administered by use of the Advanced Maintenance Management System (AMMS), which was a computerized database designed to facilitate maintenance management.
The PM part of AMMS is the Periodic and Predetermined Activity Control (PPAC).
The scope of the PM program included the major components from almost every plant system, including non safety-related systems.
PM tasks were generally developed from operating experience, environmental qualifications (EQ) requirements and vendor recommendations.
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3.3.2.1 The PM backlog appeared to be at a reasonably low level.
A review of several hundred PM activities for due dates, frequency, and last completed dates did not disclose any PM activities that should have been performed, but had not, or that were not properly rescheduled.
Several completed PPAC Rescheduling Justification Forms were reviewed for technical justification and determined to be adequate.
Evaluation of CM/PM Backlog The backlog of non-outage related CM and PM work activities appeared to be at a reasonable level, which indicated that there were no significant problems with insufficient numbers of personnel, engineer-ing support or obtaining parts.
The backlog of maintenance did not have an adverse impact on plant system operability and safety.
Management controls and involvement had been effective in accomplish-ing maintenance as indicated by the low backlog of non-outage related CM and PM work activities.
However, inconsistencies in classifying CM activities as PM or routine 11 outage 11 and PM activities as CM detracted from the accuracy of the backlogged items.
Backlogs could further be reduced by more management involvement in the process of affecting root cause analysis and corrective actions.
~eview and Evaluation of Completed Maintenance Based on previous review, the inspectors selected the Service Water System, the low pressure safety injection portion of the Engineering Safeguards System, and the Radiation Monitoring system as subjects for further review.
The purpose of this review was to determine if all specified electrical, mechanical, and instrument and control maintenance on those systems/components were accomplished as required.
The key inspection point was to determine if the 11correct 11 maintenance was 11 correctli 1 accomplished.
This was accomplished by:
0 0
0 Evaluation of the extent that vendor manual recommendations were utilized.
Evaluation of completed WOs for use of qualified personnel, proper prioritization, QC involvement, acceptance criteria, quality of documentation for machinery history and understanding of problems, and post-maintenance testing.
Evaluation of work procedures for technical adequacy, inclusion of QC hold points, acceptance criteria, user friendliness, and general conformance to NUREG CR-1369.
Review of Completed Electrical Maintenance The inspectors reviewed WOs for the following systems and components:
Control rod drive mechanisms (CRDMs), CROM position indicators, Hydrogen Recombiner, Main Exhaust Fan, High/Low Pressure Safety Injection, Service Water, High Pressure Control air compressors, miscellaneous systems, and Radiation Monitoring System.
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I Control Rod Drive Mechanisms (CRDMs) - WOs 24503691, 24600783, and 24600778.
The work type in Block No. 22 of these WOs and others was often categorized as
- 110utage, 11 which is defined as routine outage activity in Procedure 5.01, 11 Processing Work Requests/
Work Orders, 11 Revision 9.
However, most of the WOs categorized as 110utage 11 were used to repair i noperab 1 e equipment and should have been categorized as CM.
Incorrect categorization causes an incorrect ratio of PMs to CMs to be indicated.
CROM Secondary Position Indicators -
Temporary Modification No.88-052, which modified the Secondary Position Indicators (SPI) of the CRDMs to clear sporadic alarms from SPI No. 16, was in place since May 27, 1988.
The modification required that SPI No. 16 leads be lifted at the SPI datalogger, and jumpered SPI No. 17 to SPI No. 16 input to the datalogger.
A safety review of the modification was performed per Procedure 3.07, 11Safety Evaluations, 11 Revision 1, which stated in Step 5.2.5.b that a safety evaluation be performed if the function of a system or component described in the FSAR was altered. of Procedure 3.07 was a 10 CFR 50.59 applicability check, which required that four questions be answered to determine if a safety evaluation needed to be performed.
The answer to Question No. 2, 11 Does the item i nvo 1 ve a change to the facility as described i-n the FSAR?
11 was checked 11 No.
11 However, the Temporary Modification did involve a change to the SPI system as described in Section 7.6.1.3 of the FSAR and a written safety evaluation should have been performed.
The inspector noted that a similar Temporary Modification (No.86-023) was performed in March 1986, which jumpered eight SPis.
At that time, the licensee stated that the modification did involve a change to the facility as described in the FSAR and a written Safety Evaluation was performed.
Failure to properly perform a 10 CFR 50.59 applicability check required by Procedure 3.07, 11Safety Evaluation, 11 Revision 1, is a violation of 10 CFR 50, Appendix B, Criterion V.
However, an 11 unreviewed safety question 11 did not exist because the TS allows removal of one SPI indication.
(255/88020-0lA)
Hydrogen Recombiner - WOs 24505705, 24505706, 24607720, 24702248, 24705494, 24803641, and 24805460.
The inspectors identified one minor concern.
There were two Technical Specification items that involved this component; however, Block No. 24 of the WOs usually only referenced one, when in fact both should have been listed.
Main Exhaust Fan - WOs 24505399, 24700114, 24701553, 24706579, and 2480526.
10
The root cause was often not adequately addressed in the 11 Summary of Work Performed 11 Section of the WOs.
For example, on WO 24700114, Fan V-68 would not start in standby or manual.
Several component problems were listed in the summary, but resolution and root causes of those problems were not discussed, it was only documented that V-68 tested okay.
Both V-6A and V-68 exhaust fans had recent airflow failures, therefore, the licensee initiated a review of the performance history and determined that the fan blade angles had been increased by the licensee from 32° to 55° to achieve the needed suction; however, the manufacturer recommended a maximum blade angle of 44°.
The licensee contacted the manufacturer and was evaluating the problem.
However, there was no apparent technical justification or evaluation when the blade angle was initially changed from 32° to 55°.
High/Low Pressure Safety Injection System - WOs 24600406, 24601787, 24600095, 24706185, 24706777, 24707538, 24803269, and 24806112.
Some WO instructions were not detailed enough, for example, WO 24601787 and 24803269 simply instructed the electrician to troubleshoot and repair.
Problems and symptoms were poorly stated.
WO 24806112 was for replacement of a cracked resistor for the green light on the control switch for the HPSI Valve M0-3068.
The QC inspector had signed Attachment 8 under 11 Notes 11 and stated on Page 3 of the Work Order 11verified lead/link see attached sheets.
11 Discussions with the QC inspector indicated that only the lead/link sheets and drawings were verified but not the actual determination and retermination of the links.
The procedure and the lead/link sheets did noi provide for specific QC sign off points to clearly indicate what was required of and performed by QC.
Service Water System - WOs 24703398, 24706596, 24705896, 24706595, 24803527, and 2480514.
Minimal, if any, QC involvement was noted in the conduct of PM activities.
In addition, QC specified requirements were boilerplated 11 Use Controlled Material Where Required.
11 Operability test acceptance criteria and results were not clearly documented, and bases for engineering approvals to noted deviations were not documented, but were mostly done by telephone approvals.
High Pressure Control Air Compressors - WOs 24608014, 24703470, 24800821, 2480110, and 24802679.
11
L I The WOs were issued to address starting and recurring high current problems associated with the East High Pressure Control Air Compressors C-6A and C-68.
The summary of work performed noted that the compressors had a ~istory of operating with high current and that the problem was to be addressed by engineering; no acceptance criteria for motor current readings were given.
Maintenance personnel indicated that additional engineering followups were in progress to determine the reason for the recurring problems with the compressors.
The review indicated that the high current readings have existed for an extended period of time.
It was apparent to the inspector that prompt corrective action was lacking and a more aggressive approach was required to resolve these noted problems.
Also, it was noted that breaker contacts were burnt and worn; however, no root cause analysis was performed.
Additionally, CM activities were incorrectly classified as PM.
Miscellaneous - WOs 247032971, 24706306, 24706722, 24707352, and 24803206.
\\..JO 24 706306 did not document the operability test in the summary of work performed, although operability test requirements were specified for verification of breaker operation.
Also, QC review of the WO package was dated October 1, 1985, but the work was not performed until January 1988.
WO 24706722 did not address the root cause of the problem.
WO 24707352 required lifting and relanding conductors, however, no operability test or QC requirements were specified.
WO 24803206 specified to test start the pump under operability requirements.
The WO did not document whether the test was accomplished.
Also, the work order was designated as PM although the motor itself was replaced.
Radiation Monitoring System A previous evaluation by the licensee, discussed in Inspection Report No. 50-255/86035(DRP), identified that the station 1s radiation monitoring system (RIA) was in need of upgrade because of recurrent maintenance and the age of the components.
Between September 1986 and September 1988, at least 170 WOs had been written to perform maintenance on RIA system components.
Continued upgrade of equipment will reduce this burden on the maintenance staff and the attendant distraction/inconvenience to plant operations.
These needs were incorporated into the licensee 1 s 5-year plan.
During this inspection, the licensee had replaced 8 of the RIA system's 59 process and area monitors.
Typically, maintenance on the system is performed by I&C technicians; however, the mechanical and electrical maintenance groups perform any needed 12
3.3.2.2 maintenance on pumps and motors for monitors that draw samples.
The only PM performed was annual replacement of pumps and motors associated with RIA-1810 and RIA-1811, monitors of the ventilation exhaust for the East and West Safeguards Rooms, and with RIA-1809, a non safety-related monitor in the radwaste ventilation exhaust system; and monthly purging of the flow transmitter-flow element sensing lines (FT/FE-1818) associated with the stack monitoring system.
In addition to these PMs, monthly functional and quarterly operational checks were performed on ~rea and process monitors.
The monthly blowdown of the sensing lines is considered only a temporary measure; implementation and completion of a permanent fix will continue.
to be tracked as Open Item No. 50-255/86035-08.
Du~ing this inspection, the inspectors reviewed LERs and the recent maintenance history for area monitors RIA-2316 and RIA-2317, which are operable only during refueling, and provide containment isolation signal (CIS) if the monitor alarm setpoint is exceeded.
Review of the LERs indicated that since 1984 there were numerous unintendend containment isolations caused by workers bumping monitors or transporting contaminated equipment to close to a monitor, or electrical noise generated by start of a motor coupled to a malfunctioning pump.
A review of a listing of the WOs written or completed for the RIA system between September 1986 and September 1988, indicated only two WOs had been written to correct malfunctions in RIA-2316 and RIA-2317.
Licensee representatives stated that because of the recent problems with RIA-2316 and -2317, the monitors will probably be replaced before the next refueling outage.
- However, it should be noted that inadvertent CIS may still be generated unless tighter administrative controls are exerted over maintenance activities around the monitors.
Evaluation of Completed Electrical Maintenance A significant weakness was that maintenance trending did not exist for electrical components.
Inconsistent completion and inattention to detail on WOs severely hampered compilation of adequate equipment histories for analysis of adverse trends, taking effective and timely corrective action, and enhancing the process of PM.
Correction of several weaknesses could enhance the effectiveness of electrical maintenance.
These weaknesses were:
Inattention to evaluations of temporary modifications as facility changes.
Incorrect identification on WOs of CM as PM, and incorrectly specifying routine "outage" WOs for repair of inoperable equipment in lieu of CM.
13
')
3.3.2.3 I
Incorrect TS references on WOs, unclear or otherwise poorly stated problems and without symptoms, and inconsistent reference to pertinent procedures.
Unapproved adjustments to components were beyond manufacturer 1s recommendations; undocumented engineering approvals for identified deviations; and unclear operability test criteria and test results.
Untimely correction of problems with the Main Exhaust Fans, East High Pressure Control Air Compressor, and Radiation Monitoring System.
Unclear meaning of QC involvement; minimal QC involvement in PM activities.
Review of Completed Mechanical Maintenance The inspectors reviewed procedures and WOs used in conjunction with maintenance performed on various components related to the Service Water, and Low Pressure Safety Injection Systems.
The review resulted in the following concerns.
Procedure SWS-M-1, 11 Service Water Pump Removal, Inspection, and Reinstallation 11 The level of clarity and specificity of ihstructions appeared adequate to ensure effective performance.
Verification provisions appeared adequate to assure quality performance.
However, instructions for system restoration were lacking; Step 5.14, Operability Testing Requirements, did not include IST testing per approved Station Test Procedures.
Procedure SWS-M-6 11 Repair and Testing of Containment Air Coolers 11 The level of clarity and specificity of instructions appeared adequate to ensure effective performance; however, it lacked quantitative acceptance criteria and reference to supporting documents.
For example:
Steps 5.1.9 and 5.3.3 gave instructions to determine if cooling coil leakage was acceptable before continuing with work, but did not include acceptance criteria for determination of 11 acceptable 1 ea kage, 11 and Step 5.2.6 gave instructions to braze a new part in place per applicable brazing procedures, but the procedures were not referenced.
Procedure CCS-M-2 11 Component Cooling Water Heat Exchanger Maintenance 11 :
Clarity and specificity.of instructions, inclusion of quantitative acceptance criteria, reference to supporting documents, and adequacy of cautionary information were minimal.
For example:
14
Neither a precaution nor instruction was included to ensure that an applicable 10 CFR 50.59 review and safety analysis was completed before performing any repair/modification to the heat exchanger pressure retaining boundary, to ensure the heat exchanger was capable of performing its in.tended function.
Step 5.2.4 referenced a sketch in Paragraph 3.1 of Attachment 1; however, the sketch was missing, Step 5.6 did not include the method of installing the mechanical plug into the tube, Steps 5.7.2 and 5.7.4 required a pressure test but did not reference a procedure or include all necessary instructions, including acceptance criteria, for conducting the test, and Step 5.10, Operability Testing Requirement was 11 none.
11 ASME Section XI testing should have been considered as testing requirements will depend on the repair/modification performed.
e WO 24505440:
Inspect and repair LPSI Pump P-67-B.
The Summary of Work Performed was completed with good attention to detail.
WO No. 24606961:
Repair CCW piping union leakage on LPSI Pump P-67-B.
The 11 Parts 11 section listed Teflon tape stock No. 37-94161, as a qualified thread sealant.
The Summary of Work Performed confirmed that Teflon tape had been used.
Discussions with the Maintenance Superintendent and review of the site non-consumables listing indicated that the use of Teflon tape _was an error.
The Maintenance Superintendent indicated that unqualified material would be immediately removed.
WO No. 24707708:
Installation of a casing drain valve on LPSI Pump P-67-B.
Work was completed in accordance with the established guidelines and requirements, with no problems identified.
WO No. 24801906:
Rebuild Service Water Pump P-78.
The IST review block on Page 1 was marked 11 no 11 even though an ASME pressure retaining boundary was opened and appeared to require ISI testing; Operability Test Requirements did not include reference to IST testing.
15
l Valve Improvement Program The licensee made a presentation and provided descriptive material to the inspectors concerning the Valve Improvement Program.
The goal of the program was to improve the quality and reliability of valves, and the effectiveness of valve related activities.
The program was developed in 1986 and implemented in 1987.
The licensee established a dedicated group responsible for the valve improvement program, including maintenance, engineering, procurement, and reference material.
Prior to implementation of this program, out of 10,000 valves, approximately 200-300 valves were repaired annually and the rework rate was over 10%.
During 1987, over 1,000 valves were repaired and the rework rate dropped to less than 3% the first year, and six months later was approximately 1%.
The Valve Improvement Program appeared to be successful.
3.3.2.4 Evaluation of Completed Mechanical Maintenance No significant strengths or weaknesses were identified.
- However, correction of several observed weaknesses could enhance the effectiveness of mechanical maintenance.
These weaknesses were detected in both the WOs that control mechanical maintenance, and the procedures which direct specific maintenance activities.
These.
weaknesses were:
Lack of definitive acceptance criteria and other details for Operability Testing requirements and inspection activities.
Lack of reference to applicable procedures for activities beyond the skill of the craft.
3.3.2.5 Review of Completed Instrument & Control Maintenance The inspectors reviewed procedures and WOs used in conjunction with instrument and control (I&C) maintenance performed on various components related to the Service Water System, Engineering Safeguard System Including Low Pressure Safety Injection.
A historical I&C WO report was also used as reference to identify I&C activities completed in the past year.
Listed below are some of the procedures and completed WOs used to conduct I&C maintenance.
The inspector reviewed procedures RI-3 for PT-0102A, RI-95 for FT-0727A, and MSI-I-2 for LT-0103 and determined that the procedures adequately included vendor recommended practices for maintenance.
Service Water Pump Differential and Engineering Safeguard Room Cooler Temperature Indicator - WOs 24801193, 24802861, 24803933, and 24804283 16
3.3.2.6 The WO description, for all the WOs reviewed, was basically to troubleshoot and repair.
The instructions lacked detail and did not always provide the technician with adequate descriptions of problems.
However, the work appeared to have been satisfactorily performed and documented; system operability was restored.
Those WOs that related to the Engineering Safeguards Room Cooler temperature indicators indicated a possible lack of effort or knowledge on the part of the licensee to properly address the identification of problems.
In two instances, the technician determined that the device was working properly, but later it was determined that the wrong device had been listed on the WO.
Safety Injection Tank Level - WOs 24705769, 24706235, 24706289, 24706659, 24707299, 24707574, 24707617, and 24802340.
In reviewing the historical WO report, the inspector noted that the Safety Injection Tank Level alarms exhibited a high number of failures.
The licensee attributed the cause for all these failures to heating and cooling of the instrument sensing lines.
The failures included binding or broken gears in the indicators due to overranging, instrument reference legs requiring back filling due to shrink and swell, and adjustment of the indicator due to changes in the reference legs.
The inspector reviewed, Event Report E-PAL-87-015A, which was provided by the licensee in response to questions from the inspector.
This report documented the repeated failures and contained an engineering analysis to address the problem.
I&C engineering was reviewing the possible solutions including replacement of the measurement system.
Based on the licensee 1s awareness of this problem, the inspector made no further efforts to followup on this issue; however, there was an apparent lack of effort by the licensee to take timely action to resolve the problems and affect corrective action.
Evaluation of Completed I&C Maintenance No significant strengths or weaknesses were identified; however, correction of observed weakness could enhance the effectiveness of I&C maintenance.
The weaknesses were:
Inadequate description of problems on WOs.
Inadequate work instructions.
Inadequate and untimely action to correct chronic problems with Safety Injection Tank level instrumentation.
17
3.3.3 3.3.4 Engineering Support The inspectors evaluated the extend to which engineering principles and evaluations were integrated into the maintenance process.
This was atcomplished by the review of WOs, activities associated with failure analyses and other maintenance activities to evaluate the effectiveness of engineering support.
Areas reviewed were engineering support to PM, equipment problem resolutions, compliance with codes and regulations, system engineering concepts, industry initiatives, and post maintenance testing.
The System Engineering Department, though new, was committed to improvement.
The group leaders and systems engineers appeared to be enthusiastic and knowledgeable.
Systems engineers effectively followed maintenance activities that pertained to the assigned
- systems and interfaced with design ~ngineering, performance engineering, quality control, and other groups.
Reportedly, verbal communications between maintenance personnel and engineering personnel appeared good.
Discussions with engineering personnel indicated that maintenance personnel usually did not hesitate to contact engineering for assistance or resolution to problems.
However, documentation of engineering resolution to problems noted on WOs during the performance of the job was usually missing or phrases similar to 11 Engineering resolved problem 11 or "Engineer notified of problem was the only objective evidence that engineering was involved.
System engineers provided support of maintenance activities; further development will continue to improve their effectiveness and result in improved maintenance.
Verbal communications were good; however, documentation of ~roblem resolution and evaluation needed improvement.
Work Control The inspectors reviewed several maintenance activities to evaluate the effectiveness of the maintenance work control process to assure that plant safety, operability, and reliability were maintained.
Areas evaluated included control of WOs, equipment maintenance records, job planning, prioritization of work, scheduling of work, control of maintenance backlog, maintenance procedures, post maintenance testing, completed documentation, and review of work in progress.
An Advanced Maintenance Management System (AMMS) was a computerized database designed to facilitate maintenance management.
Three parts comprised the AMMS:
Equipment Database (EDB), Work Request/Work Order Process (WR/WO) and Periodic and Predetermined Activity Cor.:.rol (PPAC).
The EDB provided engineering and operational data for Plant Components; the WR/WO process incorporated maintenance planning, scheduling, and maintained equipment history; and the PPAC provided automated control of routinely scheduled tasks.
18
1 3.3.4.1 3.3.4.2 3.3.5 During the inspection, the inspector's requests for work records, equipment history, PM schedules, and other data within the AMMS were retrieved from the database in a timely manner, which indicated easily accessible files within the maintenance.management system.
Processing, implementing, and controlling Work Requests/Work Orders was administered by Plant Procedure 5.01, which was used as a reference to review and evaluate closed WOs.
The inspectors attempted to determine whether the licensee
_had adopted Probabilistic Risk Assessment (PRA) concepts in the maintenance program and in such areas as planning, scheduling, and prioritization of work.
The inspectors reviewed activities in these areas and determined that the licensee had not formally documented a program or goals for integration of PRA into the maintenance process.
This was considered a weakness.
Trending of CM and PM Procedure EM-20, "Equipment Performance Monitoring and Trending, 11 Revision 1, provided requirements and guidelines for periodic review of CM and PM activities for trends that may affect safe and reliable plant operation.
The procedure also provided basic requirements and guidelines for development of both informal and permanent records of trending program activities.
The procedure appeared to be an effective tool to perform trending; however, records of trending activities did not exist in the electrical discipline.
This was considered a weakness.
Rework The licensee had established a means to track rework of maintenance activities.
The licensee defined rework as additional effort needed to provide operable equipment for plant operation and included additional maintenance activities due to a device or component not
_satisfying post maintenance and operational testing requirements.
A monthly graph indicated baseline data and trends for the various disciplines.
The licensee provided the inspector with the six electrical reworked WOs issued in the last year.
Two had been closed and four were still in progress.
Review of the six items did not disclose any generic or specific maintenance process weaknesses.
Personnel Control As discussed in other sections of this report, the inspectors observed work performed by non-permanent plant personnel.
During those observations weaknesses were identified with the lack of attention to details of the work performed and with the way activities were 19
recorded.
Based on these observations the inspectors interviewed a number of supervisors and workmen.
The inspectors also reviewed training procedures and records, and discussed the observations with the licensee as follows:
Tne training program for contractor personnel appeared adequate.
As described in the Project Management and Control (PMC) Procedure or approved craft procedures, new employee indoctrination included general employee and radiation worker training, and required reading lists that included plant administrative procedures.
The inspectors determined that the training program for Field Maintenance Services (FMS) was weak based on observations of poor work performance.
FMS is a Consumers Power Company organization with skilled personnel that travel to nuclear and non-nuclear facilities within the company.
These workers received general employee and radiation worker training in order to work at the Palisades plant.
According to the licensee, procedures such as instructions on WOs were used throughout the company and therefore; FMS employees should be familiar with the Palisades administrative procedures; however, formal training was not required on Palisades procedures for FMS employees.
Discussions with FMS and the licensee indicated that additional plant specific 11 nuclear 11 training would be a benefit to FMS workers.
The inspectors noted that similar concerns had been identified in previous inspection reports.
Further, the recent SALP 8 report noted weaknesses in contractor training and supervision of work activities.
The licensee recognized that problems existed and was in the process of enhancing administrative controls which address training and qualifications.
A draft of a new plant procedure, 11 Training and Qualifications for Non-Permanent Plant Employees and Contracted Services Personnel, 11 was prepared and included FMS training.
The licensee 1s proposed procedure along with an awareness that weaknesses exist, should strengthen the training and performance of non-permanent plant workers.
The inspectors reviewed the training and qualification records for site QA and QC personnel, and corporate QA and technical specialist personnel that performed audits and inspection activities associated with the reports reviewed by the inspectors. *The inspectors made the following observations:
Corporate QA auditors and technical specialists had varied backgrounds, including audit and design experience, I&C, maintenance, metallurgy, radiation protection, and plant operations experience.
Plant QA auditors had a variety of experience in various engineering fields, plant operations, and constructions.
Plant QC inspectors had strong backgrounds in maintenance, four of five had previously worked as maintenance supervisors.
20
3.4 3.4.1 Contract QC inspectors had a considerable amount of nuclear plant construction experience only.
These QC inspectors were hired mainly for the outage to monitor modification activities.
QA and QC personnel had the technical backgrounds and experience to be a useful resources to ensure and improve overall plant performance, including maintenance.
Observation of Current Plant Conditions and Ongoing Work Activities Observation of Material Condition The inspectors performed plant area and system walkdowns in the containment, auxiliary building, diesel/generator rooms, control room, and intake structure to assess the general and specific material condition of the plant to verify that WOs had been initiated for identified equipment problems, and to evaluate housekeeping.
Items such as leaks, radiological controls, labeling of equipment, spare parts and tool control, tagging of equipment needing maintenance, lubrication of equipment, and equipment oil levels were observed.
3.4.1.1 Buildings/Rooms Containment The inspectors observed the following discrepant conditions that were not identified by the licensee with a 11Component Problem Identification Tag 11 (CPIT), which was used to indicate that a Work Order had been written to correct the condition:
(a) Safety Injection tank discharge valves M0-3045, M0-3049, and M0-3052, had large boric acid buildups around the valve stem, which indicated packing leaks.
(b)
Containment coolers VHX-1, VHX-2, and VHX-3 leaked water onto the containment floor.
(c)
The Shield Cooling pump, P-77A, had a mechanical seal leak.
The licensee reviewed the WO backlog and determined that WOs had been written to repair the valves and cooler leaks during the outage, but none had been written to repair the shield cooling pump.
The licensee immediately prepared a WO to repair the pump.
The inspectors observed water on the floor at elevation 590 1 by Containment Air Cooler VHX-1, and in an adjacent aisle with much foot traffic.
The water was leaking from the cooler and, apparently, overhead piping.
Plywood sheets had been used to raise welding and other equipment above the water and had also been laid in the aisle.
Licensee representatives stated that the leakage was uncontaminated 21
water from the Service Water System and that work had been scheduled to repair the leaks.
Licensee representatives agreed to mop up the floor and have drip pans installed.
Elsewhere in containment housekeeping and the layout of temporary equipment was poor; there was an inordinate amount of graffiti on walls.
Auxiliary Building The inspectors made the following observations:
(a)
Equipment with discrepancies was tagged with CPITs, which identified the WOs to be used to repair the equipment.
(b) Water on the ground floor level in the Rad Waste area approached a contamination zone boundary.
The source of the water was a leaking relief valve.
A WO had already been written to correct the leakage and the relief valve was immediately repaired.
(c)
An asphalt tar pump on the ground floor in the Rad Waste disposal area was leaking tar from the pump shaft mechanical seal.
The licensee stated ~hat a drip pan was usually placed under the leaking seal to prevent tar from puddling on the pump pedestal and the surrounding floor.
Even though the licensee was aware of the seal leakage, no CPIT was attached to the pump to identify and tr~ck equipment problems.
(d)
Housekeeping and general equipment condition were considered fair to good.
(e) Motor operated valves (MOVs), specifically located in the East and West Safeguard Rooms, were very clean and had lubricated valve stems.
The licensee 1s valve improvement program appeared to be functioning.
(f) Eight terminal block links were left open on terminal block TB-8 in the Remote Shutdown Panel.
The inspectors discussed the open link issue with the licensee and on numerous occasions requested additional information to determine why the links had been left open.
The inspectors were not successful at obtaining the information.
This item is considered unresolved pending review of that information (255/88020-02).
Diesel Generator Rooms The inspectors made the following observations:
(a) A determinated wire with a broken connector was noted on the 1-2 Emergency Diesel Generator (D/G) Air Compressor 22
(b)
Unit C-3B gasoline engine and no CPIT was attached.
This condition would have prevented the engine from starting; however, an electrical driven air compressor was available.
Review of the last PM activity performed on the compressor unit on July 8, 1988, under WO 24803079, indicated a problem with work step sequencing.
Step 09 of the work procedure required that a cup of gasoline be poured into the compressor 1 s gasoline tank and the engine started and run until the tank was empty.
Step 10 required that oil and dirt from the engine block, spark plug, and oil fill area be wiped off.
The connector was apparently broken off at this time.
Reversing Step 09 and 10 would have identified the broken wire because the motor would not have started.
The licensee took immediate corrective action to replace the broken connector.
A small stream of water was leaking from the 1-1 DIG heat exchanger water jacket cooling flange joint connection.
No CPIT was attached to or near the piping.
Subsequent to the inspector's observation of the leak, the licensee attached a CPIT and a week later replaced the flange joint on the piping.
(c)
The inspectors noted that the lubricating oil fill line (d) on the 1-1 D/G was not identified by an identification tag or label.
This was brought to the licensee 1s attention and a label was attached.
The 1-1 D/G Excitation Panel C-22 had approximately 10 terminals with 3 conductors terminated to each terminal point on Block TB-1.
The nuts that secured those termination points did not have full thread engagement.
In addition, the terminal containing the (+) and (-) DC power supply conductors, appeared to be too small.
Subsequent review by the licensee indicated that there was incorrect cable sizing for the States terminal block strip; that the DC feed to the diesel/generator Excitation Panel was a lOOA breaker with No.2AWG cable and the cable was terminated on terminal block TBl, which was a States block terminal strip that was rated for a maximum of 30A.
Subsequently, The licensee issued Deviation Report PAL-88-179 for the incorrect cable size and documented the difference in current ratings for the conductors and termination points.
This item is unresolved pending review of licensee's corrective action.
(255/88020-03).
Regarding termination of three conductors at one terminal point, Cable Termination Procedure MSE-E-12, Revision 2, stated in Paragraph 4.2.2 that no more than two terminal lugs shall be inserted under the same screw and that a 23
. )
deviation from the above required engineering approval.
The System Engineer indicated to the inspectors that.the required engineering approvals were not obtained.
Failure to follow Procedure MSE-E-12 is an example of a violation of 10 CFR 50, Appendix B, Criterion V (255/88020-0lB).
Control Room The inspectors observed that even though major outage and modification activities were ongoing, the general cleanliness of the control panels was poor.
For example, instrumentation and associated wiring was covered with an unusual amount of dust and debris.
Inside the panel on the floor was littered with wire ties, pieces of unused wire, wire markers, dirt, metal filings, and paper.
Unmarked, cut wires, fuses on the floor without tags, and partially filled out tags were observed in the control room MCB panels that contained electrical sequencers.
These problems were corrected subsequent to the inspector 1s findings.
Terminal block test link positions did not appear to be properly controlled.
For example, opened test links were Red Tagged and some were not.
Temporary Modification Tags were applied to some disconnected instrument connectors while others.were not tagged at a 11.
The inspectors also observed the inadequate control of 11 Breaker in Test 11 handswitch tags.
The tags were considered an operator aid; howev~r, the tags were not controlled as such.
As a result of the inspector 1s concern, the licensee appropriately revised Administrative Procedures No. 4.03, 11 Equipment Control, 11 and NO. 4.09, 11 Control of Operator Aids.
11 Actions taken by the licensee were considered adequate.
Turbine Building The inspector concluded that housekeeping and general equipment condition in the Turbine Building to be good except for two minor concerns.
(a)
When Condensate Pump 2B motor was removed the pump coupling area was not covered to preclude debris from falling down the equipment access and collecting in the pump coupling area where rusty water and debris had collected.
By the end of the inspection the pump motor was replaced and the area cleaned up.
(b)
The Heater Drain Pump area floor was covered with approximately three inches of water.
Piping insulation, extension cords, and other equipment were in the water.
The inspector informed maintenance personnel who found the floor drain plugged, which was unplugged and the area 24
3.4.1.2 3.4.1.3 Systems cleaned.
The inspector also observed water on the floor in other rooms in the lower levels of the turbine building.
Discussion with the licensee determined that the problem was caused by ground water seepage and an effective solution to the ground water seepage had not been determined.
Low Pressure Safety Injection System The inspectors observed that the LPSI pump, P-678, was leaking.
A CPIT was attached to the pump; however, the associated WO was not to correct the leak.
Subsequently, the licensee initiated a WO to repair the leakage.
Service Water System The inspectors made observations of the Service Water System including valves, pumps, and panels.
The inspectors were particularly attentive to lubrication, leakage, painted surfaces, and obvious signs of good maintenance practice.
The general material condition of the mechanical components was good including screen wash equipment.
However, the following deficiencies were identified:
(a) Differential pressure switch DPS-1319, used across Basin Screen 1319 for Service Water Pump P-7A, was not secured to the local panel.
The licensee documented the deficiency on a CPIT and indicated that the switch would be secured.
(b)
The local panel that contained DPS-1319 did not have a panel nameplate or designation.
The licensee stated that this particular local panel was never assigned a panel number, but that this concern would be addressed.
Evaluation of Current Plant Condition Generally, equipment problems identified by the inspectors during plant and system walkdowns had already been identified by the licensee 1 s CPIT system, or were otherwise corrected.
Overall plant conditions were poorest in the containment and control room panels.
There was an inordinate amount of graffiti on containment walls that detracted from the professionalism expected at a nuclear power plant.
Problems with ongoing electrical work were identified during the inspectors 1 walkdowns including a violation of procedural requirements.
The material condition was considered satisfactory to maintain operability of components at a level connensurate with the components 1 function.
However, more management attention to the overall order and condition of the plant and correction of the observed weaknesses will enhance the material condition of the plant.
25
3.4.2 3.4.2.l Observation of Ongoing Work Activities The inspectors observed ongoing work in electrical, instrumentation and control, and mechanical maintenance areas.
The inspectors selected these activities from the plan of the day listings, work assignments in individual maintenance shops and through discussions with individual foremen.
Where possible, safety significant activities were chosen for followup.
Work activities were assessed in the areas of management involvement, work control process, use of correct materials/parts, performance in accordance with technical and administrative requirements, clarity and use of work procedures and drawings including acceptance criteria; presence, absence, and involvement of supervision, technical support, and QC inspection; control of measuring and test equipment (M&TE), and experience and knowledge of personnel involved with the activity.
Electrical Maintenance The inspectors observed portions of nine electrical maintenance activities as discussed below.
Control Rod Drive Mechanism Maintenance During the outage, electrical PM was performed on 11 Control Rod Drive mechanisms (CROM).
The work packages required inspection test and repair, as necessary, per WO 24803214.
The wiring harnesses on 5 of the 11 packages were replaced due to brittle wires.
The inspectors* witnessed plant electricians perform an inspection of one wiring harness and noted that the insulation cracked when the wiring was handled.
The licensee commented that the brittleness was probably due to steam leaks into the CRDMs and age.
Subsequent to the inspectors questioning if all CRDMs warranted inspection due to the large percentage of CRDMs with poor wiring, members of the electrical maintenance staff made the decision to PM all 45 CRDMs.
As a result, other problems with the CRDMs were identified and repaired as follows:
defective limit switches, the synchro did not respond, limit assembly shaft bearings were replaced, and worn bearing gears at the bottom of limit switches were replaced.
Electrical maintenance personnel were in the process of checking the remaining CRDMs and replacing wiring harnesses when necessary at the conclusion of the inspection.
The inspectors noted that Neolube No. 1 was applied to gears and bolts; however, application of Neolube was not specified in the WO.
Subsequently, the electrical maintenance department verified with both the system engineer and a chemical engineer that application of Neolube No. 1 for CROM packages was appropriate.
26
Procedure.CRD-E-27, 11 CRDM Drive Package Component Checkout on Ti::st Stand, 11 Revisiori 6, was used to verify proper operation of the CRDMs and adjust the limit switch setpoints.
Procedures CRD-E-2, 11 CRDM Drive Package Component Re pl a cement, 11 Rt:::vision 11, and CRD-E-17, 11 CRDM Motor, Brake and Gearbox Inspection and Repair, 11 Revision 8, were used if repairs were needed.
WO instructions stated that procedures CRD-E-2 and CRD-E-17 should be used if repairs were needed but did not specify under what conditions the repairs should be performed, which left much to the electricians discretion and the possibility of incorrectly omitting or performing a work step.
The inspectors witnesst:::d good support from Radiation Protection personnel during the CROM work.
A Radiation Protection technician was present at several points during the maintenance to perforri1 radiation surveys and take smears of the CROM surface and wqrk area.
Main Exhaust Fan Motor, V-6A lhe inspectors observed plant electricians troubleshoot Main Exhaust Fan, V-6A, m6tor per WO 24805826.
The inspectors noted that the electrician had previously completed insulation resistance checks of the motor approximately one hour before per procedure SPS-E-7, 11 Insulation Resistance Testing of Electrical Equipment, 11 Revision O; however, the insulation resistance values had not been documented on Attachment 1, 11 Megser Test Form.
11 The electrician stated that the readings would be documented from memory after the work was completed.
The inspectors considered this to be poor practice.
Electrical Breakers PM The inspector observed FMS perform several PMs of breakers, per WOs 24805116, 24805119 and 24805275.
The electricians cleaned and inspected the breakers and performed insulation resistance testing per procedure SPS-E-7.
The inspector did not identify any problems.
Charging Pump Motor 11A 11 Pl 1~
The inspectors observed FMS personnel perform one step of
\\*10 24893224, which was a PM to refurbish the 11A 11 Charging Pump t-iotor.
FMS momentarily energized the motor to verify that the rotation was in the proper direction.
- However, the v!O did not specify the correct rotation, nor was there a directional arrow on the pump that indicated the direction of rotation.
FMS personnel documented the motor rotated in the correct direction of rotation on the WO and later verified with operations that the direction was correct.
However, a weakness existed in that the WO did not include acceptance criteria.
27
Diesel/Generator Electrical Panel Maintenance The inspector observed an electrical maintenance workman troubleshoot a discrepancy related to as-built configuration of circuits in D/G Panel G21.
The workman obtained controlled copies of the latest available electrical drawings from the document control center (DCC); however, several of the drawings were not the most current revision.
For example, Drawing 950W48M12, Sheet 96, Revision 0, was used, but Revision 1 and Revision 2 were issued.
Bot~ revisions were for hardware modifications, incorporation of replacement electrical contactors in D/G Panel G21.
The electrical contactors_ had already been installed at the time of this inspection, but the system had not been declared operable.
The inspectors reviewed the aperture card file and noted that the file only contained the superseded July 2, 1984 revision.
Neither the drawing nor aperture cards were annotated to identify that a hardware modification was in process and two subsequent revisions to the drawing existed.
Additionally,-
neither the drawings nor the aperture cards were annotated to identify that the Configuration Control Project (CCP) walkdowns of DIG Panel G321 had already been completed.
After review of Procedure 10.44, "Design Document Control and Distribution, 11 Revision 5, the inspectors determined that there was no measure established to inform the DCC that the drawing was revised and hardware modifications were in progress.
This resulted in the workman using a superseded revision to a drawing to perform work.
Failure to have measures to control changes to drawings where hardware modifications are in progress and ensure work is performed with the correct revision of a drawing is a violation of 10 CFR 50, Appendix B, Criterion VI (255/88020-04).
Diesel Generator System Modification The inspectors observed work per WO 24802607 that required replacement of contactors and installation of a new annunciator panel in the D/G, 1-1 starter bus.
The inspectors noted that procedures specified in the WO were not at the work location; neither the workman nor the QC inspector involved were familiar with the specified procedures.
Furthermore, the QC inspector was not aware that a required drawing had been laying underneath the panel so the QC inspector kept going back and forth to the workman's office to verify torquing requirements that were provided on the drawing; apparently never questioning the workman as to where the 28
workman obtained the torquing requirements.
Procedure 5.01, 11 Performance of Maintenance 11 Revision 8, Attachment 5, Item 1, required that a copy of the work order and a copy of any procedures required shall remain at the work location and; if required, be used whenever work was in progress.
Based on the above, failure to follow site procedures for having procedures at the work location is an example of a violation of 10 CFR 50, Appendix B, Criterion V (255/88020-0lC).
Further review of the procedures noted in the WO indicated that work steps had been completed several weeks prior to the inspection; however, the steps had not been signed off when completed.
Subsequently, on September 16, 1988, Procedure I-FC-627-02-001, Steps 5.2.5 and 5.2.2.2 were back dated to August 27, 1988, and Step 5.2.4.1 was back dated to August 25, 1988.
In addition, Steps 5.2.2 and 5.2.2.1 were signed as performed on August 27, 1988, and verified on August 26, 1988 (verified prior to performed).
Procedure 5.01, 11 Processing Work Request/Work Orders 11
, Revision 8, Attachment 5, required work steps to be signed off when the work was accomplished.
Based on the above, failure to follow site procedures for completing work steps is an example of a violation of 10 CFR 50, Appendix B, Criterion V (255/88020-010).
Additionally, Procedure I-FC-627-02-001, Step 5 stated 11Thi s procedure shall be performed in sequence unless authorized differently by the originator.
11 The inspector noted that steps were performed out of sequential order.
Based on the above, failure to follow site procedures for completion of work steps in order is an example of violation of 10 CFR 50, Appendix B, Criterion V (255/88020~01E).
Subsequently, the licensee presented the inspectors with a message form, which was not an official procedure change document, stating that precise order of steps was not critical.
Sequencer Replacement The inspectors observed portions of sequencer replacement activities in the control room as required by WOs 24801086 and 24802604.
The following obse'.vations were made:
(a)
Engineering Design Change No. EDC-FC-0737-10, dated September 15, 1988, was issued without a signature by the Plant Review Committee (PRC).
(b)
Step 6.6.3 of Installation Procedure I-FC-737-1, Revision 0, stated 11 Remove tags, close links, reterminate wires and install fuses that have previously been removed per Section 6.1.1, 6.1.2, 6.1.3 and 6.2.
11 Only one 29
I __
3.4.2.2 (c)
(d)
(e) sign-off step was provided for independent verification of all these activities.
The L. K. Comstock QC inspector failed to document a noted deficiency in a Non Conforming Material Report (NMR) and suggested that the craftsman resolve the noted deficiency so a NMR would not have to be generated.
The L. K. Comstock QC inspector failed to document on the checklist and attachment to E-006(Q), Report No.88-323, Revision 4, dated October 2, 1988, that two conductors had been terminated to TBRl point 20 on the new sequencer.
The completed checklist showed point 20 as not terminated.
Procedure I-FC-737-2, Revision 0, Step 6.4.7 required that the QC inspector use Table 1 on Drawing 8-9505B9-M201, Sheet 43 for the inspection of the sequencer connections; however, the L. K. Comstock QC inspector elected to use sketch SK-9595B-M201, Sheet 43 for this inspection.
Although there appeared to be inattention to detail and generally poor work practices, none of the above items had any adverse impact on safety.
Evaluation of Ongoing Electrical Maintenance Weaknesses observed include:
Use of lubricants not specified in WOs.
Some procedures lacked adequate or definitive instruction or acceptance criteria; procedures were not always followed as written, and, procedures were not always in the area where work was being performed.
Inspection and test data were not documented immediately after completing work; data points came from personal memory.
Contracted QC inspectors did not appear aggressive in assuring that quality work was performed.
Correction of these weaknesses could enhance the effectiveness of ongoing electrical maintenance.
3.4.2.3 Mechanical Maintenance E-54-A CCW Heat Exchanger Inspection The inspector observed Field Maintenance Service work on the CCW heat exchanger per WO 24803875.
were not aware of the procedure in use nor which should have been in use.
The inspector reviewed 30 (FMS) perform The workmen procedure the work
package and determined that Procedures CCS-M-2 and MSM-M-20 were included with the work package and the three workmen had signed both procedures which verified that the contents had been read and understood.
The workmen were cleaning the heat exchanger tubes with a machine that was not included in the scope of Procedure CCS-M-2.
Review of Procedure CCS-M-2 indicated that the only prerequisite signed-off was 3.4.1, which provided verification that the workers had read and understood the procedure; however, Step 1 of the WO, a prerequisite, required flow/DP data to be taken before the work started, but this data was not taken, yet work by the previous shift had completed the steps for removal of the inlet and outlet bonnets.* Step 5.2.4 of the procedure was not completed, which was intended to measure and record leakage after the preliminary pressure test.
The Summary of Work Performed was not used at all even though this was not the first crew to work on the job.
Work stopped after the workmen were unable to tell the inspector which work step was to be performed next.
The inspector was informed by the workmen and the FMS Planner that training was not provided about administrative procedures and requirements.
The inspector informed the licensee about these concerns, and subsequently, the licensee documented the concerns on Deviation Report PAL-88-038.
Based on the above, failure to follow work instructions for completing work steps is an example of a violation of 10 CFR 50, Appendix 8, Criterion V.
(255/88020-0lF)
E-548 CCW Heat Exchanger Inspection The inspector observed work in progress per WO 24803874 and noted that the work package included instructions to plug tubes as necessary, but did not refer to the need for a safety evaluation or 10 CFR 50.59 review of the modification to plug tubes.
Motor-Operated Valve Maintenance The inspector observed a portion of the PM on Motor-Operated Valve (MDV), NOD 5315, according to WOs 24707338 and 24803294.
The valve was not safety-related, but the PM instructions were generic to all MOV applications.
The WO instruction referenced the procedures to be used, but not which steps; all steps were not to be performed.
The workman had to decide which steps to use.
The workman was knowledgeable and had formalized MDV training.
The maintenance was completed in a professional manner and proper contacts were made with the shift supervisor to release the valve for testing.
No other problems were noted.
31
3.4.2.4
---~-
Emergency Diesel Generator (DIG) Maintenance The inspector observed the final phases of the overhaul of the 1-1 DIG in accordance with WO 24800076.
The overhaul included replacement of three cylinder heads.
The inspector observed reassembly of equipment after the heads were installed including valve adjustments and connection of the exhaust system.
The WO for the overhaul referenced the DIG technical manual and specified the specific steps to be performed.
Personnel who performed the work were familiar with the work.
The supervisor for the job had attended a vendor sponsored DIG training course and the mechanics had received on-the-job-training.
During testing, the DIG could not be started because the air compressor, which provided starting air to the DIG start motors, would not operate.
The inspector did not observe testing beyond the failure of the compressor to operate.
Subsequently, the license determined that the air compressor motor starter thermal. overload had tripped at some unknown time.
The thermal overload would not reset so a new thermal overload was installed.
After replacement of the thermal overload, the compressor operated until the tank pressure reached 200 psi when the thermal overload tripped.
Further tests showed that the thermal overload tripped when the compressor attempted to maintain pressure at 235 psi.
The licensee was in the process of evaluating the problem and performing additional testing with the the~mal overload relay trip settings increased by 5%.
There was engineering support of the DIG overhaul and the thermal overload problem.
The thermal overload problem is considered an open item and will be followed by the Resident Inspectors (255188020-05).
Evaluation of Ongoing Mechanical Maintenance Strengths observed included:
Motor operated valve maintenance was accomplished by experienced personnel who interacted well with operations staff.
Diesel engine maintenance personnel were well trained and qualified.
Weaknesses observed included:
Failure of FMS personnel to follow work instructions.
Inattention to detail by FMS personnel.
32
3.4.2.5 3.4.2.6 Instrument and Control Maintenance The inspectors observed portions of four I&C maintenance activities as discussed below.
In general, all tasks were performed as directed in the work packages and procedures.
The I&C technicians appeared to have a good understanding of the requirements, that is, WOs, procedures, tools, and skills needed to satisfactorily complete the tasks, and did not hesitate to seek help from supervisors or engineering staff when questions arose.
Containment Building Pressure Transmitter and Steam Generator Level Indicator The inspectors observed work on the Containment Building pressure transmitter and Steam Generator level indicator per WOs 2460763, 24803551, and 24803564.
The work was performed in a satisfactory manner and in compliance with plant administrative procedures and technical requirements.
Fuel Handling Area Monitor Work performed on the Fuel Handling Area Monitor to troubleshoot, repair, and adjust as necessary per WO 24805618 was observed to be satisfactorily performed.
This was the only job during direct observation of I&C activities where QC was contacted to inspect but QC chose to waive the inspection per Administrative Procedure 5.01, Attachment 5, Section 2.
Evaporator Control Panel Radiation Alarm A lack of WO control and inconsistencies with the plant maintenance procedures were identified during observation of work associated with WO 24608570, which was initially issued in May 1987 to troubleshoot and repair the Evaporator Control Panel Radiation Alarm.
In November 1987, a request was made to revise the WO to install a new unit per Procedure SC-87-184.
In January 1988, the new unit was installed and energized in preparation for final calibration.
In September 1988, the original May 1987 WO was reviewed and approved as still being valid.
During observation of this activity, it was noted that the I&C technicians used the May 1987 WO to calibrate the unit per Procedure RI-86B.
The updated WO for installation and calibration of the equipment had not been distributed to the field, however, the technicians had performed the required tasks.
Evaluation of Ongoing I&C Maintenance Strengths observed included:
33
3.4.3 The computerized system for controlling M&TE.
I&C technicians routinely utilized supervisors and engineering staff for guidance when questions arose.
Weaknesses observed were:
Poor WO control resulted in use of an incorrect procedure for calibration purposes.
Poor participation by QC in I&C maintenance activities.
Correction of these weaknesses could enhance the effectiveness of ongoing I&C maintenance.
Radiation Protection Support of Maintenance The inspectors reviewed the major support functions provided by the radiation protection group for maintenance including preparation of radiation work permits (RWPs); conducting ALARA reviews of proposed modifications, procedures, and work packages; and providing job coverage.
The inspectors also observed health physics coverage of certain maintenance activities, including incore cutting and CROM maintenance.
Those functions and results of the review are described below.
Maintenance work planners usually requested an RWP at the time the work was planned or shortly after the planning was completed.
Requests were processed by the ALARA group of the Radiological Services Department, who conducted an ALARA review if the scope of the job and the radiological conditions in the work area warrant a review.
For completing the RWP, the ALARA group had access to AMMS to review the work plan, including the job scope description and the person-hour estimate.
Information from previously issued RWPs and from a job history and ALARA review file was also used.
Once an RWP was issued and work begun, feedback on the need for continuation of the RWP was usually provided at least weekly to the ALARA group by the planners.
Overall, the licensee 1s RWP program appeared to provide good support of maintenance performed under an incorrect RWP.
ALARA reviews were conducted as part of the RWP write-up for work requests/work orders that involved potential or actual exposure to significant external radiation levels or could result in significant internal exposure.
The reviews were conducted by use of previous reviews, job history files, and other references.
In addition, completed RWPs and ALARA reviews may reference written work practices from the licensee 1s Radiological Work Practices Manual.
This manual was developed in conjunction with the maintenance department and was intended to define acceptable/preferred methods and techniques for performance of certain maintenance activities in a radiologically satisfactory manner and to maintain the internal and external 34
exposures of individuals involved with the activities ALARA.
The ALARA group also reviewed all maintenance procedures to ensure that radiation protection holdpoints and warnings were included in the procedure.
The ALARA group worked with the maintenance groups to establish and track RWP-specific and annual person-rem goals.
Maintenance group supervisors were regularly provided information on actual cumulative person-rem compared to goals.
Goals set for selected job-specific RWPs and for 1988 were reviewed by the inspector and appeared reasonable.
For 1988, the licensee had an overall goal of 550 person-rem; however, because of the unplanned steam generator work, the final, actual total will probably be at least 600 person-rem.
Support provided by the ALARA group for maintaining internal and external exposures ALARA included the use of temporary shielding, mock-up training onsite and at vendor facilities, stellite and volatile cleaner reduction programs, and the use of portable ventilation units to control airborne radioactive material.
A selective comparison of survey records and exposure records, and a review of whole-body count records indicated that the licensee 1s ALARA program was effective in limiting external and internal exposures of maintenance personnel considering the relatively high radiation fields and the extensive amount of contamination areas in which work is often performed.
The inspectors noted that an excessive number of personal contaminations, approximately 900, were detected since early in the outage.
Al though the 1 i censee appeared to have made a consi derab 1 e effort to investigate the contaminations, there was relatively little success in reducing the contamination until recently when the amount of outage work significantly decreased.
The personal contaminations were mostly low level, 1000 to 10,000 dpm, and did not appear to have resulted in significant personal radiation doses.
The contaminations were significant, however, because an increased overall tolerance of poor radiological work conditions and practices can occur.
In addition, the contamination events may affect worker morale.
Discussions with maintenance workers indicated that there was strong concern among the workers about becoming contaminated while working in 11 clean 11 areas of rooms and from protective clothing that was intended to reduce the likelihood of becoming contaminated.
As such, the licensee should continue to pursue this problem to resolution.
The licensee has requested onsite assistance from INPO in an attempt to resolve the problem of the excessive number of personnel contaminations.
This matter is discussed further in Inspection Report 50-255/88021.
The inspector determined that the Radiation Protection technicians were knowledgeable about the jobs and appeared to function well with the team of individuals who conducted maintenance.
Generally, support provided by the radiation protection group for maintenance activities appeared effective.
The problem with excessive number 35
- 3. !,. 4 3.4.5 of personal contaminations was a weakness that detracted from this effectiveness.
Maintenance Facilities, and Control of Measuring and Test Equipment The inspectors reviewed the licensee 1s activities in the areas of facilities, equipment, and materials to assess support to the maintenance process.
Interviews were conducted with various maintenance management and craft personnel to determine the policies, goals, and objectives; and followup observations were performed to determine the extent to which the plant practices, procedures, equipment, and layout supported the maintenance process.
The three maintenance groups, mechanical, electrical, and instrument and controls (I&C) each had separate workshop areas.
Electrical maintenance facilities were good.
The facilities were recently enlarged to provide ample space for the electricians and offices adjacent to the electrical shop for first-line supervision.
Mechanical Maintenance and I&C facilities appeared to be adequate.
Work supervisor 1 s offices in all three maintenance group areas were generally well located, relative to the workshop areas, of adequate size, and accessible.
Most of the support organization personnel and their work areas were located in the same are with the maintenance organization.
During observation of ongoing maintenance activities, the inspector observed the licensee 1s method of issuing and controlling M&TE.
A computerized system was used to record issuance of the M&TE and help prevent use of uncalibrated or outdated equipment.
When obtaining the M&TE, an equipment identification input into the computer system along with pertinent WO information.
This created a record of equipment usage.
IF M&TE was past due for calibration, the technician would be notified on the computer screen that the equipment was due for calibration and therefore, should not be used.
This system allowed a historical review of M&TE usage and was also used to determine when the equipment was due for calibration prior to the expiration date.
This appeared to be a good system for control of M&TE.
No examples of improper M&TE usage were identified during the inspection.
In general, the licensee 1 s maintenance facilities appeared to be good.
The recent additions and modifications to the shops should prove very beneficial.
Configuration Control Project The Configuration Control Project (CCP) was established to provide an accurate, up-to-date, physically verified set of design bases documents that can be used for the safe and efficient operation, 36
maintenance, and modification of the plant, and to ensure that future changes to the plant are properly justified, documented, and implemented.
The inspectors reviewed the electrical drawing verification portion of the CCP for thoroughness and accuracy of walkdowns (physical verification that the hardware conforms to the wiring diagram),
timeliness of assessments and engineering evaluations, and technical completeness of engineering evaluations.
The inspectors were informed that walkdowns of approximately 300 drawings had been completed in March 1988, and numerous discrepancies were identified.
Upon further review, the inspectors determined that the discrepancies were not properly documented as required by Project Management and Control (PMC) Procedure 13-3, 11 Identification and Tracking of CCP Discrepancies, 11 Revision 1, and that assessment, categorization, and engineering evaluations of the discrepancies had not been performed.
Failure to take timely action to document and promptly assess, categorize, and evaluate known discrepancies that have the potential to affect plant safety and operability is a violation of 10 CFR 50, Appendix B, Criterion XVI.
(255/88020-06A)
The inspector selected DIG Panel G21 for review and noted a discrepancy between Drawing 950WA48Ml2, Sheet 96, Revision 0, and the number of conductors terminated at terminal 5X3 on Terminal Block TB3.
Further review disclosed that just prior to the inspection findings, licensee personnel had identified discrepancies, including the above discrepancy.
After identifying the discrepancies, licensee personnel contacted the CCP staff and was informed that the drawing walkdown had been completed in March 1988, but the specific discrepancies had not been identified by the CCP staff.
WR 104494 was initiated by licensee personnel to document the problem and obtain resolution.
Subsequently, the inspectors reviewed results of the CCP walkdown of the drawing and noted that the discrepancies identified in WR 104494 had been marked on the drawing, but the drawing was not annotated to reflect that the discrepancies were added after the March 1988 walkdown was completed.
The failure to identify the above discrepancies and the casual approach to documenting discrepancies indicated to the inspectors that the thoroughness and accuracy of the CCP walkdowns were less than satisfactory.
During a management meeting between the NRC and the licensee on
- October 20, 1988, the licensee informed the NRC that resolutions to discrepancies identified during previous CCP walkdowns on approximately 400-500 electrical drawings would be completed by the end of 1988.
Subsequent to the inspector 1s identification of licensee 1s failure to evaluate identified discrepancies in a timely manner, the licensee conducted an engineering review and evaluation of several discrepancies 37
I identified in the March 1988 walkdowns.
During this review, the licensee initiated a deviation report,_ dated October 10, 1988, that documented an incorrect termination at Panel G 31.
Analysis by engineering disclosed that the Flow Switch for the DIG 1-2 Lube Oil heater had been incorrectly bypassed, for at least eight months.
The inspector reviewed electrical schematic Diagram 950W48M12, Sheet 97, Revision 0, and discussed the problem with the DIG mechanical system engineer who indicated that the Lube Oil Priming pump continuously runs whenever the DIG was operable, circulates the lube oil through the heater to the upper engine block to keep it warm, and supplies heated oil to the bearing upper cylinder to aid in fast startup.
The engineer stated that if the flow switch was bypassed, under certain conditions, the engine would be "stressed causing accelerated aging and possible harder starts~ but it would start".
This finding was categorized by the licensee as a Category 3 discrepancy, which has the potential to affect operation or licensing commitment.
Based on the above, licensee failure to promptly implement corrective action to resolve the deficiency that was identified in March 1988, specifically the miswiring that resulted in the Flow Switch being bypassed is another example of a violation of 10 CFR 50, Appendix B, Criterion XVI.
(255188020-068)
The inspectors examined the licensee 1s engineering methodology used to review identified discrepancies for resolution.
The inspectors and CCP design engineer reviewed the discrepancy on DIG panel G 21 point 5X2 as shown on Engine Startup DIG 1-1 motor control schematic 950W48Ml2, Sheet 97, Revision 0.
The CCP engineer had previously evaluated the discrepancy; however, the engineer informed the inspectors that CCP engineers conducted the review assuming that all schematic diagrams were accurate.
Therefore, there has been little effort to conduct comprehensive reviews of the entire circuit, rather, only the portion associated with the identified discrepancy were evaluated.
During the review of circuit 5X2 on schematic diagram 950W48Ml2, the inspectors noted that an additional portion of the engine starter motor control schematic pertaining to the Diesel Oil transfer pumps logic was shown on schematic El78, Sheet 4, Revision 1.
There was no indication that one schematic was interconnected with another which would result in a user of one schematic not being aware that the logic continued on another drawing.
The inspector determined that a more comprehensive review was needed on schematic diagrams to assure that the diagrams conformed to dispositioned discrepancies.
Additionally, during the review of schematic diagram 950W48Ml2, Sheet 97, Revision 0, the inspector noted that fuse 5Fu was rated 15A; however, the redundant fuse in the same circuit of DIG 2-1 was rated at 20A.
Review of ampacity tables indicated that for the conductor size of these circuits a 30A fuse was needed.
Discussion with the electrical supervising engineer indicated that the review would be performed by corporate engineers and take about a month.
This item is unresolved pending licensee action and NRC review.
(255188020-07) 38
3.5 3.5.l 3.5.2 The inspectors concluded that the thoroughness and accuracy of electrical drawing walkdowns was less than satisfactory, timeliness of assessments and engineering evaluations of identified discrepancies was unacceptable, and the technical completeness of the evaluations needed to be improved.
Licensee's Assessment of Maintenance (Quality Verification)
The inspector evaluated the licensee's quality verification process by the review of audit reports, surveillance reports, activity inspection reports, corrective action documents, and the combined INPO self-assessment and Maintenance Assistance Review Team (MART) report to evaluate the licensee's quality verification process.
The documents were reviewed to assess technical adequacy, root cause analysis, timeliness of corrective action, and justification for closeout of corrective action documents.
Review of Audits, Surveillances, and Inspection Activity Reports The inspector reviewed audits of maintenance, modification, inservice inspection (ISI), I&C, and corrective action conducted in 1987 and 1988 by the Corporate QA organization.
The audit reports indicated that most areas of maintenance were reviewed, including PM, maintenance interface with system engineers, modifications, mechanical and electrical maintenance activities, I&C and ISI.
The audits consisted of a review of records and documents, some observations of work activities, and plant equipment walkdowns; however, only a small number of work activities were actually observed.
The audits were not considered performance oriented because of the limited number of maintenance activities that were observed, and the limited evaluations of WOs and procedures for technical adequacy.
Even though there were audit findings that related to performance, the majority were administrative in nature.
The inspector reviewed 10 surveillance reports and 28 activity inspection reports related to maintenance, which were performed by plant QA and QC during 1988.
The surveillances appeared to be program oriented, but included some observation of maintenance activities.
Activity inspections were mainly observations of maintenance activities.
Review of Corrective Action The inspector reviewed 20 11 closed 11 corrective action documents associated with findings and observations from the audit, surveillance, and activity inspection reports that were reviewed by the inspector.
Corrective actions appeared to be adequate, the items were usually closed in one to eight months.
The inspector noted that when findings or observations were identified in an audit report, implementation of the corrective actions was substantiated during subsequent audits of the same areas.
39
3.5.3 3.6 3.6.1 The inspector reviewed the current 11 Monthly Corrective Action Document Return and Procedure Review Feedback, 11 which discussed the number of corrective action documents returned by QA to the group responsible for further corrective actions during the month, and for the year-to-date.
Also included was the number of procedures returned with comments pertaining to quality.
- Overall, 23 of 192 were returned; during September 3 of 21 were returned.
This was considered a strength for plant QA because there was a high threshold for inclusion of quality requirements.
QA also issued a periodic 11 Palisades Trend Report 11, which the inspector reviewed.
The report included Event Reports (ERs) and Deviation Reports (DRs) trends, the status of ERs/DRs, performance errors, inadequate instructions and hardware failures.
As of August 22, 1988, there were 171 open DR/ER.
Fifty-eight percent of those were open for greater than six months, two had been open for greater than forty-eight months.
Both documents appeared to be effective management tools for monitoring corrective actions, human performance errors, and equipment failures.
Review of INPO Self Assessment and MART Review The licensee performed an INPO self-assessment of maintenance between June 1 and September 1, 1987.
A MART review was performed in January 1988.
Findings and recommendations from both tasks were combined into one document and published during March 1988.
The report identified several findings and included recommendations for improvement.
As of July 1988, 106 of 381 actions.had been completed.
The licensee was actively tracking the status of the actions.
The inspectors noted that weaknesses identified during the self-assessment were similar to those identified during this inspection.* However, based on the inspector 1 s review of audits, surveillances, and activity inspection reports, there appeared to have been very little review of WOs by QA and QC personnel, which indicated that corrective action in this areas was not prompt.
Overall Plant Performance as Affected by Maintenance Plant Walkdowns General plant material condition appeared adequate; however, several conditions existed throughout the plant where adequate licensee action was not taken to identify or correct the condition.
The majority of the conditions appeared to have no direct impact on plant operability or safety; however, the type and number of the conditions were not reflective of a good plant material condition.
3.7 Management SuppQrt of Maintenance 40
"'-"~./ J
)
I 3.7.1
- 3. 7.2 3.7.3 Management Commitment and Involvement Management was committed to improve maintenance activities at Palisades.
Improvements have been recently implemented, several were in progress and several were planned for the near future.
Continued involvement and strong commitment are necessary to improve maintenance activities to the level desired by the Consumers Power Company.
A licensee conducted INPO self assessment of maintenance, performed in 1987, and an INPO MART, performed in January 1988, resulted in the identification and correction of a number of potential problems and weaknesses.
Some corrective actions were planned for future implementation; however, it was noted that interim actions to preclude recurrence was not completely effective for adherence to and adequacy of work instructions and control of contracted maintenance personnel.
The effectiveness of QA audits in the area of maintenance was considered to be weak because audits were not process and performance based even though audit personnel had diversified technical knowledge and experience.
Development of the system engineer concept was good, however, continued and increased involvement system engineers is necessary for continued improvement of the maintenance process.
Management Organization and Administration Document control was considered weak because no mechanism existed to ensure that only the latest revision of a drawing was used to perform work.
Minor problems were noted in the control and use of maintenance work order revisions.
Predictive type maintenance activities such as oil analysis and grease sampling had been implemented in some areas to provide information on needed maintenance prior to failure.
Technical Support Identification and resolution of technical issues generally appeared satisfactory.
Verbal communications within the plant staff and between the plant staff and corporate staff appeared good.
- However, thorough documentation of these issues needed improvement.
Failure analysis, scope of the PM program, human factors engineering, and post-maintenance testing was adequate, but continued attention and improvement is necessary to attain the level desired by the Consumers Power Company.
The visibility of Quality Control (QC) was very low.
Job coverage by QC personnel appeared minimal.
41
3.8 3.8.l 3.8.2 3.8.3 3.8.4 The radiological protection group's involvement in planning, support of maintenance, and man-rem exposure control was good.
However, the number and rate of personnel contamination was extremely high.
The radiological protection group's ability to resolve this problem appeared poor.
Maintenance Implementation Work Control Maintenance in progress generally appeared satisfactory and performed by knowledgeable personnel.
However, accuracy of work order instructions, following work orders and procedure instructions, and documentation of work performed were poor.
Total job packaging, including work orders, procedures, drawings and reviews appeared good.
Maintenance equipment records and history were good; however, root cause analysis was missing.
Daily plan of the day meetings were well conducted and provided a good method for restoration of interface and scheduling problems.
Work tracking, work prioritization, and backlog controls appeared good; however, inconsistencies in classifying CM and PM items and ineffective corrective action tended to confuse the accuracy of backlogged items.
Plant Maintenance Organization Control of contracted maintenance (contractors and FMS) appeared poor.
Quality control and procedural control was weak.
Training of FMS personnel was missing in the areas of work control, quality assurance, and administrative controls.
Support interfaces with engineering and radiological protection appeared good:
Maintenance Facilities) Equipment, and Material Control Recent changes, including increased space, to the shops should improve the effectiveness and efficiency of the facilities.
The control and issue of equipment, tools and measuring and test equipment appeared satisfactory.
However, increased backshift support for control and issue of measuring and test equipment could improve effectiveness and efficiency.
Personnel Control Plant maintenance staff training appeared satisfactory with the maintenance training program being INPO accredited.
42
3.9 Conclusion
- 4.
- 5.
Results of this inspection showed overall satisfactory performance in the establishment and implementation of an effective plant maintenance process by the licensee of the Palisades Nuclear Generating Plant.
Based on the review of past work activities, observations of ongoing work activities, work controls, and attempts at self assessment the inspectors determined that electrical, mechanical, and I&C maintenance and support activities were adequately performed to maintain operability of components at a level commensurate with the components' function.
However, weaknesses were identified.
Lack of prompt and effe~tive management involvement to correct problems identified by the Config-uration Control Project and lack of a mechanism to control drawings with hardware changes in progress were considered the most significant problem areas.
The inspection team's findings tended to validate those identified by the licensee during the INPO self-assessment of maintenance.
However, there was some concern with licensee action to correct some of the findings.
For example, adherence to and adequacy of work instructions and contractor controls, where future permanent corrective action was planned, interim actions had not been totally effective and the problems were recurring.
Although these weaknesses were identified, none appeared to affect plant system operability.
Some of the activities identified above were in violation of regulatory requirements as previously noted.
012en Items Open items are matters that have been discussed with the licensee, which will be reviewed, further, and involve some action on the part of the NRC or licensee or both.
An open item identified during the inspection is discussed in Paragraph 3.4.2.3.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items disclosed during this inspection are discussed in Paragraphs 3.4.1.1 and 3.4.5.
- 6.
Exit Meeting The inspectors met with licensee representatives (denoted in Paragraph 1) on October 20, 1988, at the Palisades Plant and summarized the purpose, scope, and findings of the inspection.
The inspectors discussed the likely informational content of the inspection report with regard to document or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.
43
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