ML18153C553
| ML18153C553 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/21/1991 |
| From: | Blake J, Girard E, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C552 | List: |
| References | |
| 50-280-91-03, 50-280-91-3, 50-281-91-03, 50-281-91-3, NUDOCS 9103050112 | |
| Download: ML18153C553 (9) | |
See also: IR 05000280/1991003
Text
-,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-280/91-03 and 50-281/91-03
L icense*e: Virginia Electric and Power Company
5000 Dominion Boulevard
Glen Allen, VA 23060
.Docket Nos.:
50-280 and 50-281
License Nos.*:
Facility Name:
Sec::tion
SUMMARY
Scope:
This special, announced inspection was a followup assessment of issues
identified durin9 the special maintenance team inspection conducted in the
Spring of 1990, (as reported in Report No. 50-280~281/90-07).
Results:
The assessment showed that the 1 i censee has made an effort to address the
concerns identified by the maintenance inspection team.
Increased emphasis, in*
the areas of allocation of resources, the role of risk in the maintenance process,
work prioritization, backlog controls, and post maintenance testing, was noted.
9103050112 910225
ADOCK 05000280
Q
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R. Benthall, Supervisor Licensing
- D. Cristian, Asst Station Manager for Operations and Maintenance
- J *. Downs, Superintendent of Outage .and Planning
- R. Gwaltney, Superintendent of Maintenance
- D. Hart, Supervisor Quality Assurance
- M. Kansler, Station Manager Surry
- J. Price, Asst Station Manager for Safety and Licensing
- R. Scanlan, Licensing Engineer
- E. Smith Jr., Manager of Quality Assurance
- T. Sowers, Superintendent of Engineering
Other licensee employees contacted during this inspection included
craftsmen, engineers, security force members,
technicians, and
administrative personnel.
NRC Restdent Inspector
- S. Tingen, Resident Inspector
- Attended exit interview
2.
Maintenance Ass~ssment Inspection (TI 2515/108)
This inspection was conducted to assess the effectiveness of corrective
actions taken, by the licensee, as a result of the Maintenance Team
Inspection (MTI) conducted during February and March 1990, at the Surry
Nuclear Plant as feported in R~port No. 50-280,281/90-07 *. The current
inspection of the Surry maintenance program was performed by a two-man
team during January and February 1991 utilizing the guidance given in NRc*
Temporary Instruction 2515/108.
The inspectors concentrated the assessment in the following areas: 1)
material condition of the plant; 2) maintenance areas that were evaluated
as poor, or missing, during the original inspection; and 3) areas that
were not evaluated during the original inspection.
Material Condition of the Plant is reflected in block No. 1.2 of the
Maintenance Inspection T~ee, "Perform Plant Walkdown Inspection."
Maintenance areas that were evaluated as poor, or missing, during the
original inspection were:
2
Section 3.3. Allocate Resources - Poor Implementation.
Sectio.n' 4.3. The Role of Risk in the Maintenance Process -
Missing
Program.
Section 5.5. Perform Work Prioritization - Poor Program
Section 5.7 Establish Backl_og Controls - Poor Performance
Section 5.9 Conduct Post Maintenance Testing~ Poor Program
Areas not evaluated during the o~iginal inspection that were assessed
this time included the. following:
Section 4.6. Safety Review of Maintenance Activities - Program.
3.
Previous Inspection Findings
The following adverse findings were identified by the MT! conducted at
the Surry site during February and March 1990:
.
.
(Closed)
Violation, 50-280,281/90-07-0l, Failure to Follow Procedures
for Maintenance
The licensee response dated June 21, 1990, was considered acceptable by
. Region II. This item involved violation of procedural requirements f_ or
{l) verification of a drawing used in troubleshooting against the
controlled drawing to assure it was the correct change; (2) revision of
drawings to correct breaker capacity changes ttiat resulted from
modifications; (3)-controls on Operations Department measuring and test
equipment (M&TO; and (4) incorporation of vendor information. into
maintenance procedures (e.g., Limitorque Update 89-1 was not
- incorporated).
The inspectors held discussions with cognizant licensee
personnel and verified examples of the corrective actiori~ stated in the
letter of response.
Three drawings previ~usly found to give incorrect
breaker amperages were verified to have been torrected (Drawing Nos.
11448-FE-llA, -llAC, and -llAE).
Operations M&TE located in a cabinet
near the control room and in the I&C instrument calibration lab was
examined and found to be properly identified and controlled.
Motor
operated valve maintenance procedures ECM-1503-1, ECM-1505-1, and O-MCM-
0305-02 were verified to contain changes based on Limitorque Maintenance
Update 89-1 (cited as not yet *incorporated into maintenance procedures in
the violation description).
The inspectors concluded that the licensee
had determined the full extent of the subject violation, performed the
necessary survey and follow-up actions, and developed the necessary*
corrective actions to preclude recurrence of similar circumstances. The
corrective actions identified in the letter of response had been
implemented.
(Closed)
Unresolved Item 50-280 ,281/90-07-02:
"EDG Day Tank Fuel
Transfer Line Analysis"
3
This i tern concerns a MTI Team observed difference between the
configuration (lack of flexible section) of a Day Tank fuel transfer line*
on the No. 3 Emergency Diesel Generator (EOG} and the same line on the
Nos. 1 and 2 EDGs.
The MTI Team asked for the basis for this difference,
in view of the fact that the applicable drawings indicated that the
flexible section should be included in all three lines. The licensee was
unable to find any documentation that would authodze/support the removal
of the flexible section from the No EOG.
It was presumed that at some
unknown time a maintenance activity necessitated the removal of that
transfer line.
Subsequently, it was further presumed that the flexible
section was lost or damaged, with no like replacement available, so a
ridged replacement was. installed.
As a result. of The MTI Team interest, the licensee performed an analysis
of this matter, documented in EWR 89-660E, and determined that EOG No. 3
was operable, but the lack of .flexibility could in time result in an
eventual fatigue failure.
With this concern in mind EWR 89-660 provided
a procedure for correction.
The replacement parts have been procured and
the work is awaiting a maintenance window for completion. This matter is
- considered closed.
4.
Maintenance Assessment Results
Section 1.2. Perform Plant Walkdown Inspection.
The inspectors conducted a walkdown itispection of the vital plant areas
including the Auxiliary Building and the Service Water Low Level Intake.
A significant improvement in housekeeping was noted in the Fish Screen
Pump Structures.
The licensee has addressed many of the walkdown items
noted by the M1I Team however the Auxiliary Building lower levels still
needs improvement.
Five MTI Team items were identified with deficiency
.tags, but were not entered into the computer system so no action was or
could be taken.
Corrective action was tak~n on a number of specific
items but similar deficiencies exist in other areas.
Some examples are:*
missing fasteners in electrical boxes; missing washers on equipment; pipe
caps left adrift; uncollected leaks; corrosion on battery terminals;
loose battery connections; thermometer left in a battery;
inoperative
lighting; and portable wheeled. equipment not secured.
On balance the
inspectors noted some improvement, and consider housekeeping and material
condition in general satisfactory.
Section 3.3 Allocate Resources
The inspectors assessed the licensee's allocation of resou~ces through
general observations of plant materiel condition and more detailed
examination of the conditions of and actions being taken to maintain the
Instrument Air (IA) and the Heating, Ventilation and Air Conditioning
(HVAC) Systems.
The IA System (Containment IA in particular) and .the
HVAC System were cited in the MTI as representing examples where
inadequate resources _had been allocated.
Based on their assessment the
inspectors concluded that the licensee's allocation of restiurces should
now be rated satisfactory in program ~nd implementation.
4
Walkdowns of the IA and HVAC Systems' along with other areas of the plant
revealed generally good equipment appearance.-
Some unsatisfactory
conditions were observed~ as described with regard to Section 1.2 above,
but these were considered mi nor as compared to the overa 11 plant
condition.
In some instances both IA and HVAC equipment showed age, as
through rust and other corrosion that had clearly occurred over a long
period of time.
With few exceptibns loose scale from the corrosion had
been removed and paint had been applied where appropriate to improve
appearance.
Some small air leaks were observed in the HVAC System.
Recent IA and HVAC improvements were observed such as new valves and
fittings at some locations in the IA lines, new ducting and bearings for
HVAC equipment, etc.
Discussions with the IA system engineer revealed that the Containment IA
continued below industry standards but that actions were being undertaken
to significantly improve its air quality.* These actions would apparently
require one or two refueling outages.
The licensee plans to replace the
current Containment IA source with Turbine Building IA, which has
relatively good air quality capabilities.
The Turbine Building IA has
sufficient capacity and could now be easily connected to provide
Containment IA.
However, Containment IA is currently recycled and use of
Turbine Building IA would not include recycling, requiring removal of the
air through th~ Containment vacuum system.
Recent testing indicated that
the Unit 1 vacuum system could not remove sufficient air.
This was
believed due to leaks in the system or insufficient pumping capacity,
which cannot be assessed or corrected during operation.
The system
engineer indicated they intend to perform maintenance on the Unit 2
Containment vacuum system during the refueling outage later this year and
perform the test to determine if it can accommodate Turbine Building IA.
The inspectors found evidence of various actions undertaken to maintain
and improve the IA System in the fourth quarter 1990 system engineers
report and in the record of work orders completed on the system since
November 1, 1990.
The record showed 93 work orders completed on the
system, over half of which were preventiv~ maintenance.
Discussions with the HVAC system engtneer indicated overall improvements
in the system but that some areas of significant weakness remained.
A
review of the licen.see's five year plan revealed planned and/or already
undertaken work such as fan motor replacements, upgrading, etc.
The
inspectors also noted scheduled improvements to many other systems in
this plan (e.g., the Emergency Diesel Generator Air Start System).
Recent significant HVAC work included Main Control Room and Emergency
Switchgear Room air conditioning improvements under Design Change 90-15.
The inspectors observed evidence of some of the improvemerits, such as
Unit 1 relay room HVAC equipment modifications which had reportedly
reduced temperatures and the rate of relay failures.
Negative
indications of the application of resources to the HVAC System included
preventive maintenance not being performed due to a lack of personnel,
delays due to a lack of parts, and the large number of work orders
currently open.
The inspectors review of a computer printout of the
licensee's current backlog of HVAC System work orders revealed about 450
5*
open work orders, which appears high compared to the 102 that. were
reportedly (system engineer's report) completed.the last quarter of 1990.
About 25 percent of the work orders closed during that quarter were for
preventive maintenance and the current backlog was found to contain a
similar number.
The system engineer informed the inspectors that
preventive maintenance work orders were no longer *being accomplished as
near the end of 1990 due to insufficient personnel (in subsequent dis-
. cussions with plant management the inspectors were informed that this
condition would be remedied).
Approximately 30 of the work orders in
the current backlog were awaiting receipt of parts.
The inspectors found .that the licensee had not prepared any formal
evaluation of the condition or maintenance needs of the _IA or HVAC
Systems either in response to the MTI or as part of the system engineers
normal activities.
The inspectors considered this a weakness and
licensee management was informed of their concern.
The inspectors had
anticipated that reports of system status and proposals for correction of
deficiencies or impending deficiencies in system capabilities would be
summarized on a periodic basis, perhaps annually, as a routine system
engineering function.
- *
The inspectors judged the licensee's program for allocation of resources
and its implementation to be satisfactory taking into account the
specific IA and HVAC System findings noted above as-well-as their
observations of the condition of other plant systems and equipment.*
Section 4.3 The Role of Risk in.the Maintenance Process
The inspectors assessed the licensee's program for considering risk in
prioritizing ma_intenance by discussions with cognizant personnel, such as
the corporate Director of .Maintenance Support; and by reviewing the
prioritization process prescribed in the station administrative procedure
for work requests and work orders ( Procedure No. VPAP-2002).
The
inspectors found that the 1 i censee
I s current programmatic requirements
did not provide for any detailed consideration of.risk in prioritizing
maintenance, but that they did (through VPAP-2002) take into account risk
to a limited degree.
The highest priority (Priority 1) was specified to
be assigned to work items which would place a unit in a Limiting
Condition for Operation; affect Technical Specifications; potentially
cause the loss of the unit, redundant systems, or equipment; or *
potentially endanger station personnel or the public. The second hi~hest
was assigned to work whose immediate completion was less critical but
still involved some risk, such as work items that affect or could
potentially affect system or equipment degradation.
The inspectors
judged these requirements to provide a satisfactory consideration of risk
but with need for improvement.
More detai 1 ed understanding and
categorization of priorities on the basis of risk appears desireable.
Also, as noted in the Section 5.5 discussion below, the licensee has not
formally established scheduling requirements based on priority.
The
licensee was found to have work in process to more formally consider risk
in maintenance as through development of reliability centered maintenance.
6
Section 4.6 Safety Review of Maintenance Activities
The inspectors assessed the licensee's program for integration of safety
- into the maintenance process through discussions with the plant
Supervisor of Safety and Loss Prevention and examination of examples of
documented programmatic instructions.
The program was shown to be
prescribed in the risk management portion of the corporate Policy and
Procedure Manual.
Based on discussions with the supervisor referred to
above, the program implemented at Surry included the following:
A full time supervisor and one contractor, as-well-as two part-time
coordinators to fmplement the program
Safety orientation provided to new employees
First aid teams manned by volunteers
A computerized accident report
Walkdowns utilizing checklists to identify unsafe conditions and
employee practices (unsafe practices observed are recorded and the
involved individual is corrected the first time the practice is
observed - the individual's supervisor is notified in the event of
recurrence)
.
.
Weekly safety meetings for each department except Admi ni strati ve
Services
Quarterly trend reports to identify any significant adverse trends
The inspectors reviewed.the checklist used in walkdowns and found that it*
contained individual items to be checked which included assurance of
proper lighting and ventilation, storage of hazardous materials, use of
electrical tools, fire equipment, etc.
The inspectors also examined an
example of a completed trend report, which appeared to . be properly
completed and informative.
Based on their discussion and review of the safety program as described*
above, the inspectors judged that the licensee had a good program for
integration of safety into the maintenance process.
Section 5.5. Perform Work Prioritization
The MTI identified, as a significant weakness, the fact that the licensee
had no effective prioritization program which was the basis for the
rating of "Poor" for the area of Perform Work Prioritization - Program.
The MTI Team noted that the prioritization scheme as it existed in
February 1990 considered only time as the basis for maintenance
prioritization, and did not consider any of the following factors:
Technical Specification LCO limitations; safety of equipment; safety of
personne 1; or impact on unit generation capacity.
The l i cerisee has
overhauled the maintenance work manag~ment system, which is documented in
7
VAP-2002, Work Request and Work Orders
11
, dated 07 /01/90.
VAP-2002
considers the factors that the MTI Team i dent.i fi ed as * absent in the
previous prioritization scheme.
There does. not appear to be a clear
connection however, between prioritization and scheduling in the present
scheme.
The inspectors consider the new scheme to be a considerable
improvement over the previous scheme, however the priority codes appear
to be too broad to be an effective tool in scheduling work.
Section 5.7 Establish Backlog Controls.
The MTI, identified as a significant weakness, the ineffective control of
the maintenance backlog, as evidenced by an increasing backlog, which was
the basis for a rating of
11 Poor
11 for the area of'Establish Backlog
Control - Implementation.
The. licensee has, since the MTI, made a
concerted effort to enforce the maintenance
11 Plan of the Day
11 (POD) work
schedule.
During the MTI in March of 1990 the licensee was completing
approximately 40% of the items scheduled in the POD., by January of 1991
they are completing approximately 85-90% of POD scheduled items.. The
average age of non outage Corrective Maintenance (CM) Work Orders (WOs)
in January 1990, was approximately 183 days (from a population of 2756),
the average age of non outage C_M WOs in December 1990 was 255 days ( from
a population of 2700).
While the total non outage backlog *(including
both Corrective Maintenance (CM) and Preventive Maintenance (PM)) has
increased by approximately 10% over the past year, the PM to CM ratio has
doubled.
The average daily WO completion rate has increased from 40 to
46 over the peri ad of the last year.
The CM backlog represented
approximately 84 days of work In January 1990, and represents
approximately 77 days of work in January 1991.
It appears that the
licensee is better managing the maintenance backlog as evidenced by_
higher scheduled work completion, doubled PM to CM ratio, the increase in
the WO completfon rate, and the decrease in the time to work off the
backlog.
It does appear that the nature of the backlog is changing in
that the average age is increasing, indicating that the newer WOs are
worked first.
Section 5.9 Conduct Post Maintenance Testing
The MTI, identified as a significant weakness, the lack of an adequately
defined Post Maintenance Test (PMT) program, which was particularly poor
in the electrical maintenance area, and was the basis for a rating of
11 Poor
11 for the area of Conduct Post Maintenance Testing - Program.
At
the end of the MTI, the licensee orally committed, to the Team, that as
temporary corrective action, which would be immediately implemented, they
would require qualified electrical system engineers to specify all PMT on
followers involving electrical work, until their new program is
implemented.
The preceding was documented in NRC Report 50-280,281/90-
07.
It was the NRC
I s understanding that an engineer qualified in
electrical testing (not necessarily a degreed electrical engineer) would
specify electrical PMT.
The licensee, not wanting to require a degreed
electrical engineer to specify electrical PMT, only required a system
engineer to specify electrical PMT (no mention of electrical testing
experience was made).
The licensee documented the same in VEPCO letter
8
Serial No. 90-329A dated October 26, 1990.
Subsequently, the licensee
has established, reviewed a.nd approved, by engineers qualified in
electrical testing, among others, a program with a generic matrix for the
selection of appropriate PMT for electrical maintenance work, for use by
planning personnel who are not engineers qualified in electrical testing.
The licensee indicated that they will implement a computer based matrix
with 10,640 of approximately 13,000 specific Q-List components, by April
15, 1991.
The licensee indicated that they would add the remaining 2,360
Q-L ist components as opportunity, and funds permit. It appears that the
PMT program definition inadequacies have been marginally corrected by the
generic matrix,* and should be fully corrected by the specific computer
based matrix~
There 1till remains a question as to the adequacy of the
electrical PMT specified prior to the implementation of the generic
matrix.
This issue will be examined by a region based electrical
inspector qualified in electrical testing.
5.
Exit Interview
The inspection scope and results were summarized on February 1, 1991,
with those persons indicated in paragraph 1.
The inspectors described
the areas inspected and discussed in detail the inspection results.
Although reviewed during this inspection, proprietary inf~rmation is not
contained in this report. Dissenting comments were not received from the
licensee.
- -*-. --- - .