ML19354D730
| ML19354D730 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 12/05/1989 |
| From: | Cummins J, Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19354D726 | List: |
| References | |
| 50-458-89-04, 50-458-89-4, NUDOCS 9001020084 | |
| Download: ML19354D730 (50) | |
See also: IR 05000458/1989004
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APPENDIX B
U.S. NVCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-458/89-04
Operating License: HPF-47
Docket: 50-458
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Licensee: Gulf States Utilities Company
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P.O. Box 220
St. Francisville, Louisiana 70775
Facility Name: . River Bend Station
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Inspection At: River Bend Station, St. Francisville, Louisiana 70775
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Inspection Conducted: September 18 through October 17, 1989
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Inspectors; m
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. Cummins, Team Leader
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, Reactor Inspector, Operational Programs
Section, Division of Reactor Safety
Team Members:
C. J. Hale, Senior Quality Systems Engineer, Material and Quality
Programs Section, Division of Reactor Safety
W. B. Jones, Resident Inspector, Project Section C, Division of
Reactor Projects
D. L. Kelley, Reactor Inspector, Test Programs Section, Division
of Reactor Safety
T. O. McKernon, Reactor Inspector, Operational Programs Section,
Division of Reactor Safety
F. M. McManus, Consultant
L. T. Ricketson, Health Physics Inspector, facilities Radiological
Protection Section, Division of Radiation Safety and Safeguards
D. H. Schultz, Consultant
R. B. Vickr y, Reactor Inspector, Operational Programs Section,
Di isio of Reactor Safety
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Approved:
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J.iE. Gag Vardo, Chief, Operational Programs
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Section, Division of Reactor Safety, Region IV
Inspection Summary: Special, announced maintenance team inspection conducted
September 18 through October 17, 1989 (Report 50-458/89-04),
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9001020084 8912i5
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Areas-Incpected: A Nuclear Regulatory Commission (NRC) team inspected
maintenance programs and the performance of maintenance activities
(safety-related and balance of plant), including overall plant performance
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related to maintenance and management support and implementation of
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maintenance. The inspectors used the NRC Maintenance Inspection Guidance,
dated September 1988, and Terporary Instruction 2515/97, dated November 3,
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1988.
Results: The-inspectors concluded that the licensee's maintenance process
consisted of generally well-developed programs with an appropriate level of
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management involvement so that the process functioned to maintain plant
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components available to perform their intended function.
J' wever, the
inspectorsidentifiedanapparentviolation(threeinstancesofafailureto
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follow procedure as discussed in Section 3.1.3) and observed that certain
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clements in the_ licensee's programs and implementation could be strengthened,
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- The following unresolved items were identified and are discussed in this
report: .
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ower oscillations associated with flow control valve
Uncontrolledp(Section2.3.3),and
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oscillations
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Required documentation not available to justify Valve IE12*MOVF024A torque
switchsettingsbelowminimumvalue(Section3.1.3).
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EXECUTIVE SUl W RY
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. A team of Nuclear Rcgulatory Commission (NRC). staff conducted a
performance-based inspection of the maintenance process at River Bend Station
from September 18 through October 17, 1989. The purpose of.this inspection was
to determine whether components, systems, and structures at the River Bend
Station were adequately maintained so that they will perform their intended
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function when required.
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The inspection was conducted in accordance with the guidance provided in
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Temporary Instruction (TI) 2515/97, 'Taintenance Inspection," dated November 3,
1988.
In accordance with the guidance in TI 2515/97, the team color-coded a
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" maintenance inspection tree" that identified for inspection the major elements
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associated with effective maintenance. The tree was used as a visual aid
during the exit meeting to depict the results of the inspection.
The inspectors. evaluated three major areas:
(1)overallplantperformenceas
affected by maintenance, (2) management support of maintenance, and (3)
maintenance implementation.
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The inspectors concluded that River Bend Station had developed a maintenance
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program that implemented the significant attributes of en effective maintenance
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process. However, the team identified the following strengths and weaknesses
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that are documented in the report and were discussed with the licensee during
the exit meeting:
STRENGTHS
'Gooddedicatedmaintenancestaffthatitorkedasateemwithwelldefined
areas of responsibility.
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Strong management' involvement in all phases of the maintenance process
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including corporate managers and supervisors at the work site.
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Communications between corporate and plant management and between
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maintenance organizations onsite was generally good.
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Good effective scheduling of maintenance activities including the
coordination of other activities which could be impacted (i.e.,
surveillancetesting).
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Adequate, well implemented maintenance programs and other programs that
interface with or support maintenance.
Craft personnel were generally skilled, knowledgeable, and competent and
documented maintenance activities well.
Outstanding maintenance facilities.
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Good quality centrol planning and involvement in maintenance activities.
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A strong maintenance enhancement program, which even though it was not
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formalized, appeared to be an enhancement to the overall maintenance
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process.
WEAKNESSES
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Craft not performing all the steps in the maintenance work orders and
marking the steps.not applicable without eny documented justification.
Identified cases in which potential problems were documented in
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naintenance work orders, but no paper trail was provided to ensure that
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the problems were addressed or-corrected.
Two instances in which documentation did not accurately reflect what had
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actually occurred.
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Apparent use of the circuit testing, lifted leads, and jumpers procedure
to isolate equipment in lieu of the protective tagging procedure, which
gave.the >otential of changing component or system status in the field
without t1e control room being knowledgeable of the change.
Inappropriate control of contracted maintenance activities in the field
and review of their completed work packages.
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Personnel entering the radiologically controlled area through entries
other than.the control point, which did not ensure that the control of
radiologically controlled area was maintained.
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Poor training and qualification requirements for system engineers.
Inadequate control of electrical safety equipment and insufficient
training on the use of this safety equipment.
Root cause determination of emergency safety features actuations not being
performed.
Several instances of insufficient instruction guidance in work plans.
Excessive number of quality assurance finding reports (OAFRs) open for
more than a year.
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TABLE OF CONTENTS
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EX ECUT I VE Summa ry . . . . . . . . . . . . . . . . . . . . . . . . . . .
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INSPECTION DETAILS. ... . . . . . . . . . . . . ... . . . . . .-. .
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Overall Plant Performance Related to Maintenance . . . . . ., .
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1.1.. Scope". . . . .-. . . . . . . . . . . . . . . . . . . . . .
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1.3 Findings. . ... . . . . . . . . . . . . . . . . . . . . . .
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1.2 Conclusions . . . . . . . . . . . . . . . . . . . . . . .
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Management Suport-of Maintenance . . .:. . . . . . . . . . . .
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l2.1 Management Commitment and' Involvement . . . . . . . . . .
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Scope .-. . . . . . . . . . . . . . . . . . . .
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2.1.2
Conclusions . . . . . . . . . . . . . . . . . .
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2.1.3'
Findings. . .'
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2.2 Management Organization and Administration. . . . . . . .
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2.2.1-
Scope
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2.2.2.
Conclusion. . . . . . . . . .. .-. . . . . . . .
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2.2.3
Findings. . . . . . . . . . ..... . . . . . ...
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12.3. Technical Support . . . . . . . . . . . . . . . . . . . .
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Scope . . . . . . . . . . . . . . . . . . . . .
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Conclusion.
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2.3.3.
Findings. ._. . . . . . . . . . ... . . . . . .
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Maintenance' Implementation . . . . . . . . . . . . . . . . . .
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3.1 Work Control. . . . . . . . . . . . . . . . . . . . . . .
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3.1.1
Scope . . . . .'. . . . . . . . . . . . . . . .
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Conclusion. . . . . . . . . . . . . . . . . . .
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3.1.3
Findings. . . . . . . . . . . . . . . . . . . .
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3.2 Plant Maintenance Organization. . . . . . . . . . . . . .
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3.2.1
Scope . . . . . . . . . . . . . . . . . . . . .
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3.2.2
Conclusion. . . . . . . . . . . . . . . . . . .
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3.2.3
Findings. . . . . . . . . . . . . . . . . . . .
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3.3 Maintenance Facilities and Materials Control. . . . . . .
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Scope . . . . . . . . . . . . . . . . . . . . .
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3.3.2'
Conclusion. . . . . . . . . . . . . . . . . . .
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3.3.3
Findings. . . . . . . . . . . . . . . . . . . .
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3.4 Personnel Control . . . . . . . . . . . ... . . . . . . .
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3.4.1
Scope . . . . . . . . . . . . . . . . . . . . .
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3.4.2
Conclusion. . . . . . . . . . . . . . . . . . .
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3.4.3
Findings. . . . . . . . . . . . . . . . . ... .
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Exit' Interview . . . . . . . . . . . . . . . . . . . . . . . .
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ATTACHMENTS
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'PERS0tlS CONTACTED
B.
ACRONYMS-
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.itAINTENANCE TEAM INSPECTION PRESEllTATION TREE
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INSPECTION DETAILS
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1.
OVERALL PLAtlT pERFORP.ANCE RELATED TO !!AINTENANCE
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1.1 Scope
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The inspectors reviewed River Bend Station's operating history data and
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performed system and plant walkdowns as direct, observable indicators of the
effective implementation of maintenance. These areas were inspected based on
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the premise that overall plant performance with respect to plant operability,
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equipment availability, and general reliability can be related directly to the
effective implementation of maintenance.
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1.2 Conclusions
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The inspectors concluded that the licensee had implemented an effective
maintenance program. However, the inspectors considered the lack of thorough
root-cause identification of emergency safety feature actuations (ESFAs) a
weakness.
It appeared to the inspectors that weekly walkthrough inspections
conducted by plant management personnel could be strengthened if specific area
responsibility for housekeeping and material condition was assigned to
individuals. Although the oil leakage areas were wiped up, the licensee needed
.to implement a concentrated effort to correct the oil leakage problem.
1.3 Findi_ngs
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Data gathered from NUREG-0020, " Licensed Operating Reactors: Status Summary
-Report," licensee monthly operating reports, and licensee operating statistics
for the first 47 months of plant operation showed a decline in the number of
forced-outage hours with a corresponding increase in on-line operating hours
without any unusual operating characteristics. The majority of the
forced-outage hours occurred at the beginning of plant operation.
The work order backlog was not overly large and the work-off rate had
maintained the backlog at a level desired by management. The licensee did not
trend maintenance rework, which made it difficult to assess the effectiveness
of plant maintenance activities.
RiverBendStationhadexperienced33unplannedautomaticshutdowns(scrams)
during its first 47 months of critical operation.
Five additional scrams were
planned as part of plant startup testing. Approximately one-half of the
unplanned scrams occurred from initial criticality (October 31,1985)to
commercial operation (June'6, 1986).
The inspectors reviewed the above data for unplanned scrams through December
1988. The licensee initially identified 336 root causes of these scrans;
however, 286 of these root causes were eliminated. Three additional unplanned
scrams occurred from January 1989 through September 1989. Three(possibly
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four) of all these scrams had a maintenance-related activity identified as one
of the root causes.
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There were 66 ESFAs, or aartial actuations, over the last approximately
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2-1/2 years. However, t1e data base contained only a brief description of the
events. Discussions with licensee personnel revealed that ESTA root-cause
identification and correction did not receive the same level of rigorous
examination as scrams. The examination of the limited data showed that possibly
seven of the actuations nay have had a maintenance-related root cause.
The inspectors selected the normal service water, standby service water, and
residual heat removal systems for system walkdown inspections. The genera)
condition of the components _of these systems was considered satisfactory. The
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major components of these systems were observed to be properly lined up for the
plant operating mode. However, the inspectors noted the following
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deficiencies;
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The standby service water pump shafts and coupling were rusty.
Several valves either had no tags or still had construction tags attached.
Many tags were attached with light-weight wire twisted at the ends instead
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of with small diameter cable and crimps as seen in other areas of the
plant.
(There was a plant-wide labeling effort under way.)
The service water piping and pipe supports, as well as other system piping
and supports, in Tunnels D and E had external rust because preservative
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coatings of paint had not been applied.
(There was a plant-wide painting
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effort under way to correct this situation.)
Of the 10 service water boot seals in Tunnel D, 6 were found with water in
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them, apparently from rain water seepage through deteriorated construction
sealing between buildings.
There were minimal areas of radiological contamination in the auxiliary and
turbine buildings and most areas were accessibic in street clothes, which
demonstrated the licensee's attention to contamination control.
The general condition of the plant areas and equipment was satisfactory
although the inspectors noted the following deficiencies:
The lighting was poor in Tunnels D and E and the residual heat removal
pump rooms.
There were oil leaks on all three main feedwater pumps, the
electro-hydraulic control pump skid, the generator hydrogen seal oil skid,
and Division I and II diesel generator engines, and, to a lessor extent,
the high-pressure core spray (HPCS) diesel generator engine.
There were large amounts of unused, unsecured scaffolding stored next to
the suppression pool suction valve of the HPCS and in several other
locations on elevation 84' of the auxiliary building.
There was graffiti in several locations, including the north wall of the
Train A room for the standby gas treatnent system.
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There was an unsecured.-.inserv. ice hydrogen bottle in Calibration-
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Rack ICMS-BAK20A. A chain was available but'was not being:used.-
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' There were~ accumulations of dirt'and small debris under equipment in
less-traveled areas of the plant.(i.e, water treatment area; off gas
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refrigeration equipment;--standby service water cooling tower).'
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2.
MANAGEliENT SUPPORT OF 14AINTENANCE
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The objective of this part of the inspection was to assess licensee
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management's support of the maintenance process with respect to the
establishment, implementation, and control of an effective maintenance program.
The major areas evaluated were management's commitnent to and involvement in
the organization and administration, allocation of resources, and technical
support provided to the maintenance process,
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The inspectors' concluded that management at River Bend Station had developed
and implemented adequate programs to provide appropriate support to the
maintenance process and that menagement at all levels was actively and
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appropriately involved in the process,
2.1 Hanagement Commitment and Involvement
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2.1.1 Scope
The inspectors reviewed the licensee's application of industry initiatives.
They evaluated the licensee's programs for reviewing, implementing, and
tracking industry operating experience. The inspectors also reviewed the
licensee's programs for tracking, trending, and evaluating plant performance
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trends, human performance evaluations, and actions-taken with regard to
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motor-operated valves (MOVs) maintenance and diagnostic testing. The
inspectors interviewed selected managers and employees to ascertain whether
these individuals understood their assigned responsibilities.
2.1.2 Conclusions
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The inspectors determined that the licensee's application of the industrialized
initiatives program, which was well documented, was sufficiently proceduralized
and adequately functioning. Management's oversight of plant activities was
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highly visible with responsibilities and authorities clearly defined. However,
the licensee was having difficulty in applying operations experience in the
evaluation of plant events, in trending root causes identified in condition
reports, and in reducing backlogs related to the nuclear plant reliability data
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system (HPRDS).
P.1.3 Findings
Managers attended daily meetings, assigned problem resolution responsibilities,
and frequently visited job sites and performed plant tours.
The licensee participated extensively in the Institute of Nuclear Power
Operations' (INPO) initiatives with regards to maintenance. The inspectors
reviewed selected parts of the documentation related to INPO maintenance
assistance visit, outage management visit, and annual plant evaluation as well
as the documentation for the INPO-assisted self-assessment. The licensee
contributed personnel to assist in maintenance peer evaluation programs at
other facilities and at INP0 workshops.
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'The licensee was using a maintenance enhancement program (MEP) that had not
been formalized. The inspectors discussed the program with licensee personnel
and reviewed the MEP evaluation sheets. The purpose of the MEP was to evaluate
the strengths and weaknesses of the River Bend Station managers, including
maintenance discipline foremen. These evaluations were considered at the time
of each manager's annual appraisal. Although recently implemented, the program
appeared beneficial and established a well-understood basis for managers'.
goal-related efforts and their agreed-upon expectations. The licensee had not
implemented the MEP at the craftsmen-level.
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The licensee established tracking measures for regulatory issuances, nuclear
steam supply system vendor information, equipment vendor information,
10 CFR Part 21 notifications, nucicar plant reliability data system
information, and for issues generated by the Nuclear Management and Resources
Council and the boilir.g-water reactor owners group.
The licensee also was strengthening the significant operating experience
report (50ER) tracking and NPRDS programs as a result of deficiencies
identified in a recent INPO plant evaluation visit. The inspectors found these
corrective actions generally sufficient.
The licensee initiated a diagnostic testing program for MOVs in response to
GenericLetter(GL)89-10,datedJune 28, 1989. This program was a followup to
GL 85-03, which resulted in the testing of 22 high-pressure core spray and
reactor core isolation cooling valves during the second refueling outage. The
licensee's systems engineering group identified 238 MOVs that will require
testing during the next refueling outage (Refueling-3) or 5-year period,
whichever is later. This timetable required testing of 80 to 90 MOVs during
planned outages and 30 to 40 MOVs during the operating cycle; however, it does
not account for test failures, repairs, or retesting. The licensee expected
the baseline MOV signature data by December 1989, which will allow about 1 year
for the initial 30 to 40 MOV tests.
The inspectors noted that the licensee anticipated that field engineering would
lose about 14 contract engineers by December 1990, with 6 requisitioned replace-
ments planned. The inspectors discussed their concerns with the licensee
personnel about staffing levels affecting the implementation of the M0V testing
programs.
The licensee developed and implemented an independent safety engineering group
responsible for trending condition reports and reviewing the reportability
requirements for these condition reports. There were a number of events during
1908 and 1989 that resulted in actuations and, at times, equipment damage.
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Several of these events (i.e., approximately 33 percent) were attributable to
either human error, lack of procedural adherence, inadequate procedures, or
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insufficient job planning. Examples of these types of events include:
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Licensee Event Report (LER)89-003, which resulted in the failure to perform a
Technical Specification surveillance properly because of inadequate procedure
development; LER 89-015, which resulted in a reactor protection system half-scram
actuation and isolation of the residual heat removal shutdown cooling suction
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valve because of inadvertent grounding of a test jumper; and LER-89-027, which
resulted in the automatic initiation of the standby service water pump because
ci an inadequate surveillance test procedure.
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The licensee's program for check valves included 102 check valves that were
greater _than 2.5 inches in diameter and which had failed the design review
criteria. The design review criteria was based on the minimal fluid velocity
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requirements of Appendix X to Stone & Webster Engineering Company's Valve
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Selection Guidelines and the proximity of the installed check valves to areas
of turbulent-induced flow. The licensee did not calculate the minimum velocity
for each valve type as described in the Electrical Power Research Institute
(EPRI) Guidelines.. Valves less than 2.5 inches in diameter were not considered
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because of the historically low frequency of failure.
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09 ting the first refueling outage, the licensee disassembled the check valves
that had been identified for disassembly during the inservice test (IST)
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program (Relief Request 24 for Q-Class I check valves). A sampling of each
group of check valves was disassembled and inspected in accordance with the IST
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plan. Before the second refueling outage, the licensee selected 32 check
valves to be disassembled and inspected.
If a check valve failed the
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inspection, additional check valves of similar design and application were
identified for disassembly and inspection. Of the 32 valves originally
selected, 9 were actually disassembled and inspected.
Because of previously
identified problems or because they failed the local leak rate test 32
additional valves also were disassembled and ins)ected. Of the 41 valves
disassembled,12 involved service water system c1eck valves. As a result of
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this inspection, five additional check valves have been added to the check
valve program. The licensee has not established a program for disassembling
and inspecting check valves less than 2.5 inches in diameter not covered by IST
Relief Request 24.
The licensee was developing an acoustical emission monitor (AEM) program es a
part of the predictive maintenance program for identifying degraded check valve
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performance. This program was expected to be implemented by the first quarter
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of 1990
The licensee was working with EPRI and other utilities to evaluate
degraded check valves in the laboratory, using the AEM program prior to
utilizing the program in the field. Engineering procedures were being
developed to control the AEM program. Any check valves, identified by the AEM
program as degraded or inoperable will be disassembled and inspected during the
next appropriate outage.
The licensee had not established a trending program for the check valve
monitoring program. However, an industry wide trending program was under
development by the Nuclear Industry Check Valve Group. The licensee was
developing maintenance procedures for each type of check valve that would
include a data sheet that could be used to establish positive and negative
trends in check valve performance.
As a member of the Nuclear Industry Check Valve Group, the licensee was
represented on the steering committee. This group was working with different
agencies and organizations to provide a forum for joint discussions and
resolution of generic check valve issues through the exchange of technical
information related to application, testing, and maintenance of check valves.
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2.2 fianagement Organization and Administration
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2.2.1 Scope
The inspectors reviewed maintenance program coverage; policies, goals, and
objectives for maintenance; allocation of resources; definition of maintenance
requirements; performance measurements; the document control system for
naintenance; and the maintenance decision process,
2.2.2 Conclusions
The inspectors concluded that the licensee had developed and implemented
adequate maintenance programs that were reviewed and updated. These programs
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included provisions to ensure the establishment of a long-range maintenance
plan, appropriate monitoring of performance goals and objectives, clearly
defined responsibilities, and an appropriate allocation of resources. The
licensee's document control system for maintenance was adequate to control and
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track documents. Licensee management involvement was demonstrated in the
excellent control over day-to-day maintenance decisions and throughout the
maintenance process.
2.2.3 Findings
Maintenance Program Coverage
The licensee established and implemented the maintenance plan through
Administrative Procedures ADii-0023, " Conduct of Maintenance," and ADM-0028,
" Maintenance Work Order." These procedures were updated on an annual basis and
clearly define the responsibilities of each manager and supervisor. Discussion
with maintenance supervisory personnel revealed that each individual was
cognizant of their responsibility.
The licensee's system outage schedule provided a 3-month look ahead for system
outages to allow adequate time for scheduling of maintenance activities and
intervice testing. Outage work was scheduled in advance for each possible
plant condition. The schedule was periodically updated and distributed to
maintenance supervisory personnel.
Appropriate management personnel attended plan-of-the-day meetings during which
management goals and objectives were clearly stated.
Establishment of Policies, Goals, and Objectives for Maintenance
The licensee esteblished a performance monitoring program through River Bend
Nuclear Procedure RENP-0028, " River Bend Station Performance lionitoring
Program." This program assessed measurable attributes such as unplanned
reactor automatic shutdowns and forced outage rate. Selective elements of this
program were distributed to the Chief Executive Officer on a regular basis.
Licensee management personnel discussed performance trends with the plant staff
and established goals based on trends and objectives.
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The plant manager and assistant plant manager of maintenance were provided with
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maintenance performance graphs on a weekly and monthly basis. This information
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included unscheduled maintenance staffing hours, maintenance work orders
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available for work, and estimated vs. actual maintenance staffing hours and
work completed vs. scheduled work.
The plant manager and assistent plant manager of maintenance held weekly
meetings wit'e supervisory personnel to discuss these performance graphs.
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Responsibi dty for meeting the established goals and objectives was clearly
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established.
Allocation of Resources
The inspectors reviewed records and maintenance item backlogs to evalusta the
control of maintenance resources as well as the allocation of field engineering
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personnel to support naintenance activities.
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The licensee had maintained the number of maintenance work orders and
preventivemaintenance(PM)tasksattheirestablishedgoalsof650and500
respectively. The licensee used contract craft level maintenance personnel
minimally during nonoutage periods except to support special activities such as
sealing leaking valves.
The inspectors found that contract personnel were being used in the engineering
breas of system engineering, predictive maintenance, PM review, and updating
the NPRDS. The licensee anticipated reducing the number of contract
engineering personnel over the next 15 months, which may adversely affect many
of these maintenance support functions. The work load on the remaining system
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engineers will increase as they are required to assume the responsibility for
edditional systems.
For example, the adequacy of the PM program was based on
the adequacy of the PM review efforts in which the responsible system engineer
reviewed the maintenance and preventive maintenance tasks for his/her system.
Definition of Maintenance Requirements
The inspectors reviewed the work package for-implementation of the maintenance
program for the penetration valve leakage control system (PVLCS) and the safety
, relief valve system (SVV). The inspector found that preventive and corrective
maintenance, surveillance testing and inservice testing programs were well
implemented for the PVLCS and SVV.
The inspectors observed implementation of the predictive maintenance program.
Field engineering had been required to perform vibration monitoring on a
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circulating water pump and operations requested vibration monitoring of a
reactor plant component cooling water pump. The ability to trend vibration
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data for each point monitored on the pump and motor was well illustrated in
each case.
It appeared to the inspectors that revision of the predictive
maintenance program procedure was needed to ensure actual practicet were
accurately reficcted in the procedure.
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' Conduct Performance Measurements
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The licensee implemented a maintenance enhancement program that involved a
quarterly evaluation of maintenance supervisory and foremen personnel. The
program was still under review for craft personnel because of contract
limitations.
Plant management used key plant perfornance indicators to monitor important
P
trends. These performance elements were described in Procedure RBNP-0028,
" River Bend Station Performance Monitoring Program." The trends were discussed
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with plant staff personnel on a weekly basis.
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It appeared to the inspectors that additional performance monitoring was needed
for maintenance job planning, contractor control, and root-cause analysis.
The maintenance job planners did not observe the maintenance activities that
they had planned. No formal feedback mechanism was established to inform the
applicable job planner of problems encountered by maintenance personnel during
the performance of the maintenance activity.
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At the time of the inspection, the ISEG had recently started trending condition
reports and assigning failure codes. The lack of a trending program appeared
to have resulted in a number of clearance violations by contractor personnel.
The NPRDS was approximately 10,000 staffing hours from being fully implemented.
The present root-cause component failure analysis methods being used by the
system engineers was labor intensive and susceptible to error by the user.
It
appeared to the inspectors that PH program task reviews will need to be closely
monitored by management personnel as the individual system engineers work load
increases over the next year.
Document control System for Maintenance
The licensee's Administrative Procedure ADM-003, * Development, Control, and Use
of Procedures," established the licensee's administrative controls for
development, revision, approval, control, and use of procedures. The
inspectors verified that changes to procedures received the same icvel of
review as the original document. The inspectors reviewed over 100 work
documents,during this inspection, in all cases the licensee was able to
retrieve the required documents.
Maintenance Decision process
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The licensee has established guidelines for the scheduling of surveillance
activities. The surveillance schedule identified system outages 3 months in
advance. This schedule was provided to maintenance, operations, and engineering
for comment before final approval. The licensee held weekly planning meetings
to plan the maintenance activities for the following week. The maintenance
activities that required a system outage were planned to correspond to the
surveillance outage, which resulted in a reduction in system outages.
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A plan-of-the-day meeting was held in the morning and evening to plan any urgent
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maintenance work items. All the different plant disciplines attended these
. meetings, which ensured that all departments were aware of the planned activities.
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2.3 Technical Support
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2.3.1 Scope
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The inspectors reviewed documentation, held discussions with plant engineering
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and management personnel, attended daily management meetings, and examined
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in-progress and completed meintenance activities to ascertain the adequacy of
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-communication channels.
Interviews with selected managers and employees also
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were conducted to verify that individuals understood their assigned responsibilities.
2.3.2 Conclusions
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-The licensee demonstrated good communications internally at the plant and with
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corporate-level management. Although the licensee's preventive naintenance review
program was effectively established, the implementation of this progran needed
strengthening. The trending process appeared to be improving, but plant
management's reaction to indicated negative trends was weak.
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The licensee integrated radiological control considerations into the planning
.and scheduling process and implemented radiological control programs that
effectively supported maintenance of the plant and gave appropriate consideration
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to as low as reasonably achievable (ALARA) concerns. However, ALARA maps used
for maintenance prework briefings did not have adequate detail of the work area
to orient workers unfamiliar with the facility.
The licensee's program to integrate regulatory documents in the maintenance
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process appeared well established and effectively implemented. The licensee
developed and implemented programs that were effectively integrating quality
control and quality assurance into the maintenance process.
However, procedural
adherence was sometimes lacking; preventive maintenance monitoring was not
tracked and trended effectively; and affirmative response actions to negative
trends appeared to be lacking.
2.3.3 Findinos
Communications
The inspectors attended daily plant meetings at the plant management and technical
staff level and at the maintenance discipline foreman / craftsmen level.
In addition,
the team observed weekly outage scheduling / planning meetings ard on one occasion
observed the facility's review committee evaluation of the emergency diesel
generators operability status, which was the result of a questionabic surveillance
test performed during a past outage. The inspectors noted that the meetings
were well orchestrated and displayed excellent internal communications.
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Discussions with' plant management and a review of documentation indicated that
good plant-to-corporate communications existed. The maintenance departments
communications with technical support appeared adequate although the inspectors
noted some exceptions in the health physics and operations areas.
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Engineering Support
(1) Preventive Maintenance and Inservice Testing Programs
The inspectors examined selected preventive maintenance and IST activities
performed during the last 2 years on the PVLCS and automatic depressurization
system (ADS). The inspectors reviewed applicable vendor manuals to ascertain
the maintenance requirements for each component located in the PVLCS and ADS.
They then compared vendor recommendations to the equipment qualification
maintenance and surveillance requirements for the two systems.
In each case,
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the licensee had established a preventive maintenance task to maintain the
equipment opereble.
However, the inspectors noted that the licensee had not established PM
requirements for the check valves located in the PVLCS and ADS. These check
valves are all less that 2.5 inches in diameter. As discussed earlier, the
licensee's check valve performance monitoring did not cover valves less than
2.5 inches in diameter.
The inspectors reviewed the IST requirements for the PVLCS and ADS to ensure
that the applicable check valves were being verified operable.
In each case,
the licensee tested the check valves in accordance with IWV-3521 of Section XI
of the American Society of Hechanical Engineers Boiler and Pressure Vessel Code
(ASMECode).
The licensee has developed and implemented an effective predictive maintenance
program in the areas of vibration and oil analysis. These programs were
identified in Plant Engineering Procedures PEP-003, " Vibration Program";
PEP-0039, " Lubricating 011 Analysis Program"; and PEP-0040, " Insulating 011
Analysis Program." The licensee planned to develop predictive maintenance
programs for grease analysis and thermography.
Approximately 300 components that were located in safety and important-to-
reliability systems were being monitored under the vibration program. Spectral
data, wave forms, and trends were taken for each point monitored. Performance
program and testing engineers performed the analysis. Reports of adverse
trends were generated by the computer analysis program and subsequently
distributed to the system engineers and maintenance and operations personnel.
Degraded rotating components including a circulating water pump motor bearing
and an alignment problem with a feedwater pump speed increader, have been
identified through this program since the completion of the second refueling
outage in June 1989.
The oil analysis program monitors lubrication and transformer insulating oil.
The licensee was monitoring 46 components for lubrication oil analysis and 31
transformers for insulating oil integrity. The results were trended and
reports of adverse trends distributed to the appropriate personnel. During the
second refueling outage a dissolved-gas analysis of the preferred "A" station
transformer identified the presence of acetylene in excess of the alert limit,
which indicated that electrical arcing was occurring within the transformer.
The licensee subsequently replaced the transformer during the refueling outage,
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The inspectors reviewed the PM review progren, part of the licensee's PM
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program, and the implementatior of PMs into the maintenance program. The
licensee's FM program was effectively established and was controlled by
Procedure MSP-0003, " Preventive 11aintenance Program;" however, the PM review
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program, as established in Procedure PEP-0044, " Preventive Maintenance Review,"
had not been well implemented.
The PM review program was esteblished to determine the effectiveness and
adequacy of the PM program on the basis of component maintenance and
operational history. The findings of these reviews were to be used to correct
existing PM procedures or to write new PM procedures, as required. The
licensee had selected 23 significant systems based on their importance to
safety, their reliability, and their associated operating problems. The
licensee was developing an equipment data list for each of the 23 systems. The
licensee planned to use this list to evaluate the importance of each component
to determine if the component should be included in the PM review for the
system. The licensee designated 10 systems for review of rotating equipment
only. The licensee completed review of 7 of the 10 systems designated for the
" quick review." The inspector reviewed the 21 Pli change recommendations that
resulted from the PM review program for the reactor water cleanup and off-gas
systems. The PM change recommendations were sent to the maintenance department
on_ January 24, 1989; as of October 1989, none of the recormended changes had
been implemented into the PM program.
The program for evaluating PMs required the plant performance and test group to
develop an equipment data list for components of each system. The appropriate
system engineer reviewed the equipment data lists and prioritized each
component according to its effect on operation or safety. The maintenance
history of that component was then evaluated to determine if changes to the PM
program for that component were needed. No formalized method existed for the
system engineer to receive feedback on proposed PM changes from maintenance and
operations before the change request was issued. The inspectors also noted that
the PH change forms were not uniquely identified to allow tracking the status
of the PM change request.
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The licensee had developed a program to identify required PM tasks resulting
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from plant modifications. Engineering Procedure ENG-03-006, " River Bend
Station Design and Modification Request Control Plan," established a
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meintenance checklist that included any necessary revision to the PM program
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for changes made to plant equipment. The maintenance discipline supervisor had
responsibility for determining changes to the PM program; an engineering
evaluation of the maintenance requirements was not performed as with the PM
review program.
The inspectors reviewed modification requests, MR 87-0639 and MR 88-0088, which
authorized the installation of " live-load" packing of approximately 140 valves.
Many of these valves were located in the drywell and steam tunnel.
The
inspectors noted that the maintenance checklist did not identify any new PM
requirements for the live-load packing. The inspectors further noted that the
Bellville washers used to compress the packing tend to relax over several years
and can result in degradation of the packing assembly. The vendor only
guarantees the packing for 5 years.
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(2) Field and Design Engineering Group
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The licensee established two groups within the engineering organization at
River Bend Station: the field engineering group performed long-term projects
such as performance monitoring and system engineering, and the design engineering
group performed short-term projects and provided specialized technical support
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in such areas as system design and environmental qualification. The engineering
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staff consisted of approximately 100 design engineers, including contractor
personnel, and 82 field engineers. The licensee planned to reduce the number
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of contracted engineers over the next 15 months.
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The inspectors observed good engineering support of some maintenance activities,
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for example, planning of work that was to be done in accordance with the ASME
Code end support in the field of the Division I emergency diesel generator
outage on October 3, 1989.
(3)EvaluationofproblemsbyEngineering
The licensee had experienced reactor recirculation flow coolant valve (FCV)
operability problems during the second operating cycle. The inspectors reviewed
two condition reports (Condition Reports 89-0042 (nd 89-0043), dated January 18,
1989, which documented flow centrol problems resulting in single loop operation
to effect repairs to the flow control system. The ISEG conducted a study of
the single loop operations and the two events that occurred (Condition
Reports 89-0042and89-0043) on January 18, 1989. 'lhe results of the study were
documented on July 21, 1989, in Operating Event Report 89-004
The ISEG report
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and the condition reports documented power and flow oscillations resulting from
the malfunctioning flow control system. The oscillations resulted in reactivity
changes that would have produced a reactor scram (flow bias trip) if the
operator had not intervened.
It was decided to conduct a more indepth review
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of these events and, therefore, this issue was classified as an onresolved item
(458/8904-01) pending further HRC review.
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(4) . System Engineers
The inspectors noted indications that there were program and implementation
weaknesses in'the system engineering area.
A majority of the system engineers did not maintain a day-to-day knowledge of
their assigned systems. They were not required to review condition reports or
maintenance work authorizations on their assigned systems, nor to witness
post-maintenance testing or surveillance performed on their assigned systems.
The system engineer did perform the required inservice testing en their assigned
systems. They had not received detailed training on their assigned systems.
The inspectors noted that some component training, such as on the reactor core
isolation cooling system turbine, had been provided from the vendor.
The system engineers were not trained on, or provided with, previous system
experiences that had been identified through NRC bulletins, information notices,
or significant operating experience reports.
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Qualification cards had not been developed for each system engineer position
except for the low-pressure core spray qualification card, which was developed
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but not implemented.
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The' system engineers did not keep maintenance histories on each system current,
which would make the backup system engineer less effective if the primary system
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engineer was not available.
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Role _of Probabilistic Risk Assessment (pRA) in the Maintenance Process
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The licensee expected to complete integration of the first level of the PRA for
- River Bend Station into the maintenance process by Jenuary 1990.
Role of Quality Control / Quality Assurance (QC/QA) in_the Maintenance Process
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~ The inspector reviewed selected MWO document packages to verify that they were
in compliance with the licensee's controlling procedures.
Maintenance work orders fell into two classes, corrective and preventive. All
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corrective MW0s were inspected by QC as applicable, but preventive MW0s were
only sampled or monitored according to a predetermined schedule. The QC
inspection coverage for corrective MW0s was appropriate and the monitoring of
preventive MW0s exceeded the number scheduled.
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While these actions showed strong QC involvement in the MWO process, a weakness
was observed in that the preventive HWO monitoring was not being formally tracked
so that management could readily assess its compliance schedule, nor were
monitoring inspection results being assessed to determine if future monitoring
schedules should be adjusted.
QC personnel were required to inspect the MWO document package against a checklist,
contained in procedure 001-3.7, " Quality Control Inspection Planning," Revision 4.
This checklist was required to be completely filled out and any problems resolved
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before release of the package for work by maintenance personnel. However, an
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inspector examined an MWO package (R116231) of work already completed and noted
that it contained a checklist that was only partially complete.
By the time
the inspectors discussed this matter with QC personnel on October 3, 1989, the
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subject document package had received a final QC inspection before turnover to
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permanent plant files and the checklist had been completed.
It was apparent to
the inspectors that the checklist was completed late, but the checklist did not
indicate who made the late entries or when they were made. This issue has been
referred to the licensee for resolution.
The trending process and the trend reports, which were issued every 6 months,
showed a constant improvement over each preceding trend period. While this
aspect of the licensee's trend program may be viewed as a strength, plant
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management's reaction to indicated negative trends was weak. For example, a
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negative trend for design engineering during the last 6 months of 1988 continued
to worsen during the first 6 months of 1989 and the first apparent engineering
management reaction to this negative trend did not occur until mid-1989,
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Integration of Radiological Controls Into the Maintenance Process
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Thelicensee!slevelofintegrationofhealthphysics(HP)intotheplanningand
scheduling' process appeared to be adequhte, but according to licensee represen-
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tatives, communications and' relationships between HP and maintenance personsci
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were not good in the past, but had improved with tim and were now satisfactory.
The inspectors discussed this with maintenance personal and learned that main-
tenance personnel felt that HP personnel should be involved in work preparation
earlier. HP personnel told the inspectors that typically there was little or
no delay in preparing radiation work permits (RWPs) and that, under the current
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procedures, they could not initiate RWPs for maintenance work. HP personnel
felt that potential delays could be avoided with earlier submission of RWP
requests with complete and accurate information.
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The inspectors reviewed selected training records of licensee personnel and found
i theseworkerswerecurrentinGeneralEmployeeTraining(GET)Iand11,which.
included training for radiation workers, and GET III, for respiratory protection.
Some workers had been given miscellbneous radiation protection training and
GET IV, which emphasized the problems of radioactive contemination. Licensee
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representatives stated that all mechanical maintenance personnel were intended
to receive GET IV. One of two maintenance planners and schedulers, whose records
were reviewed, had also been give specific ALARA training in which mockups of
valves and. piping eere used in the practical portion of the training and-in
preparatien for outage work.
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Radiologichi training was accredited and satisfied the commitments contained
in the USAR and-the requirements of Technical Specifications 6.3.1'and 6.4.
Plant personnel could enter the radiologically controlled area (RCA) with an
access radiation permit for the purpose of touring the area. They were
required only to check with HP before entering the area; there was no sign-in
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procedure. The inspectors noted numerous ways of entering and exiting the RCA
without passing through the main access point. Although the potential exists
for workers to exit through these alternate routes and bypass contamination
monitors, the. inspectors did not observe specific instances of such. Work
performed in the RCA was donc 00 under either standing RWPs or RWPs written
specifically for a particular job, depending on the assessment performed by HP.
The inspectors attended a prejob briefing given to two contractors in
preparation for sealing leaking valves in a steam-affected high radiation area.
The briefing was given by the ALARA technician and an HP technician and
included expected radiation levels, precautions to reduce radiation dese,
allowed staying time, clothing requirements, dosimetry requirements, pathways
to be followed, and general orientation to the area.
Survey maps were used by
HP personnel for prejob briefings.
However, these ALARA maps lecked the detail
necessary to be helpful to a person unfamiliar with the area in which work was
to be done.
The licensee had developed and implemented good ALARA programs and HP personnel
apoeared to have a good personal rapport with maintenance planners and
schedulers.
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Worker awareness of the ALAP,A~ concept and involvement'in maintaining low
radiation doses appeared good as was evidenced by the submission of 25 ALARA
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suggestions in 1988.
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The radiation exposure history is provided below.
RADIATION HISTORY IN MAN-REM
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HAINTENANCE
TOTAL STATION
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YEAR
ALARA-GOAL
ACTUAL
ALARA G0AL
ACTUAL
1986:
50
82.367
26.7
46.610
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1987
285
378.000
197.27-
193,529
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1988
100
99'.360
35.00
38.54
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Safety-Review of Maintenance Activities'
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During September 18 through 22, 1989, the inspector informed the licensee that
-high-voltage gloves, which were stored in operations equipment lockers, were
not consistently being stored inside their protective canvas bags when not in
u se'.
The licensee subsequently posted the equipment lockers with instructions
to verify test / inspection date is current, inspect and air test rubber gloves,
-ensure leather protectors are on gloves, restore the gloves in bags, return the
equipment to the locker, and lock the locker.
During the week of ~0ctober 26, 1989, the inspector observed that two lockers
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were unlocked when not in use. One locker was empty and. the other had all the
safety equipment properly stored. While o)erators were racking circuit-
breakers out of high-voltage switchgear, tie inspector observed that the
~ operators.did.not seem familiar with the posted instructions nor the recognized
method of inspecting and air-testing of rubber gloves. The inspectors'
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discussion with the-operators revealed that, although the operators had been
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specifically' trained in the mechanics of breaker removal /reinsta11ation and
informed of the need'to use the safety equipment, the operators had not been
specifically trained in its inspection, storage, and care--other than required
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reading of the. licensee's-safety manual. The licensee agreed that the
conditions observed by the inspector were unsafe work practices.
-and Health Act (OSHA) practices appeared to be contrary to Occupational Safety
The above unsafe work
requirements of 29 CFR, Chapter XVII, Section 1926.951,
" Tools and Protective Equipment " Paragraph (a),"ProtectiveEquipment,"
(1)(ii)(1)(iii),"Inaddition,anairtestshallbeperformedforrubbergloves
" Rubber protective equipment shall be visually inspected prior to
use."
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prior to.use.'"' This issue has been referred to the licensee in accordance.
with NRC Information Notice 88-100, " Memorandum of Understanding Between NRC
and OSHA' Relating to NRC-Licensed Facilities," and HRC Inspection Manual,
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LChapter 1007, " Interfacing Activities Between Regional Offices of NRC and
OSHA."
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Integration of Regulatory Documents into the Maintenance Process
The licensee had established and implemented programs and procedures to control
the receipt, logging, and tracking of regulatory documents. The licensing
group assigned responsibilities for tracking as well as routing the documents
to.the applicable disciplines for review, Regulatory documents that required
licensee action were submitted to a work scope committee for scheduling,
planning, and analysis. Regulatory documents that required proceduralizing
were sent through the administrative support group assigned to the applicable
discipline for procedure revision.
The inspectors reviewed the licensee's actions in response to Generic Letter (GL) 85-03, " Motor Operated Valves (MOVs)"; GL 89-10, "MOV Diagnostic
Testing Program"; and GL 88-75, "Antipumping Circuitry on Safety-Related
Circuit Breakers." The licensee had performed adequate reviews, assigned
action responsibilities, appropriately tracked items, responded in a timely
manner, and, where applicable, incorporated appropriate activities into plant
that the utility was timely with licensee event report (LER) porting indicated
prograns/ procedures. A further review of operating event re
submittals.
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MAINTEllAllCE IMPLEMENTATION
The objective of this part of the inspection was to determine the extent of
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control of (1) maintenance work; (2) plant maintenance organization programs;
(3) maintenance facilities, equipment, and material; and (4) personnel,
in these
areas the inspectors observed maintenance jobs in progress, reviewed programs, and
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work packages, interviewed personnel, and observed activities that support
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maintenance (i.e., material and personnel control).
The inspectors concluded the licensee had developed and implemented appropriate
work control programs for maintenance. The facilities and work spaces were very
-good and conducive to the effective performance of maintenance activities. The
licensee had developed and implemented effective personnel control programs
and routinely reviewed staffing to ensure that requirements were being met.
The licensee's training and qualification programs for maintenance personnel
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were adequate. More specific conclusions are discussed under each area.
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3.1 Work Control
3.1.1
Scope
-The inspectors assessed the work control process by reviewing maintenance in
progress, including work orders, post-maintenance testing, and adherence to
procedures; equipment records and history; work prioritization and backlog
controls; and completed work control documents.
3.1.2 Conclusions
The inspectors concluded that work control programs were adequate. Craft and
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first-line supervision were good in the electrical and instrument and control (I&C)
disciplines, but-lacked procedural control in the mechanical discipline. The
implementation of training for work planners was weak.
Equipment history was
well maintained and retrievable although there were disparities in recordkeeping
and tracking of specific components. The inspectors considered the licensee's
scheduling and control of the work backlog to be a strength, but believed the
process for prioritizing work could be improved. The post-maintenance test
program was adequate, but the licensee's MWO review program needed strengthening.
3.1.3 Findings
$intenanceinProgress
The inspectors were concerned about the weaknesses in the licensee's process
for controlling lifted leads. Licensee employees expressed concern that the
absence of a formal program for controlling lifted leads made it difficult for
the shift supervisors and shift foremen to adequately know the condition of the
plant and its safety systems. The inspectors learned that Procedure ADM-031,
which was in effect during initial plant startup, had effectively controlled
~
lifted leads.
However, the procedure was cancelled after the plant went into
commercial operations. On September 28, 1989 (during the inspection), a
technician lifted a lead during maintenance on a solenoid control valve for a
ventilation damper. The technician was not aware that the lifted lead also
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powered otherfsolenoid' valves. When the-lead was lifted, five additional
solenoid. valves were deenergized and their associated air dampers unexpectedly
,
changed position. More effective controls on lifted leads would have prevented
-this event.
The inspectors'also were concerned that the licensee did not have an effective
process for the shift-to-shift oversight of clearances, tags, and lifted leads.
Shift 4urnover did not always result in an effective turnover or review of the
outstanding clearance tags and' lifted leads as was observed during the performance
w
of Maintenance Work Order Request (MWOR) 130425. Maintenance was initiated on
penetration valve in the main steam isolation valve leakage control system (PVLCS)
The Crew B foreman (night shift) had accepted a clearance
onOctober4,)1989.to isolate the compressor check valve being worked on. A badly
(RB-1-89-2483
eroded disc had caused the-improper compressor output pressure, and work was stopped
by the Crew 8 foreman until the work plan could be revised and replacement parts
obtained. The day shift foreman received the revised work plan and conducted a
crew briefing. However, the inspector noted that the clearance sheet had not been
signed in the " Checked and Accepted By:" block (Block F) by the day shift foreman.
The inspector questioned the day shift foreman about his responsibilities concerning
acceptance of the clearance from the night shift foreman and was advised that the
day; shift foreman did not have to accept the clearance from the night shif t foreman.
Although the day shift crew had started work, work had tn be stopped because
isolation could not be obtained and water was leaking into the check valve.
Later in the day, the inspector noted that the clearance document had been
changed to reficct that the day shift forenan had " accepted" the clearance on
the morning of October 4, 1989. However, after reviewing the card reader
access records, the inspector concluded that the dey shift maintenance foreman
had not " accepted" the clearance in accordance with Procedure ADM-0027,
Revision 7,'" Protective Tagging," before releasing his crew to perform system
maintenance. The day shift foreman later admitted to the inspector that he had
tance of the clearance until the afternoon. This is an
notsignedforaccep(458/8904-02).
apparent violation
The licensae initiated a condition report to
further investigate this problem of Procedure ACM-0027.
The inspectors reviewed the clearance:, that were active at the time of the
inspection and noted that many clearances had been issued to organizations-
rather than persons. A review of Procedure ADM-0027, " Protective Tagging,"
paragraph 3.6, indicated that, "A requester may also be by title (i.e., Shift
Supervisnr, Control Operator Foreman, Maintenance Foreman, etc.) as long as
they comply with Step F.1 of Attachment 7 of this procedure." However, several
instances were noted in the active log of clearances in which organizations
rather than persons wera indicated. The inspectors considered this practice
inconsistent with the intent of Procedure ADM-0027, paragraph E.1., Attachment
7, which stated, " CLEARANCE ISSUED TO - The name of the Forenan the Clearance
is issued to will appear in this block.
In the absence of the Foreman, a
Clearance can be' issued to an individual designated by the Foreman or
supervisor to be in charge of the work." The team concluded that the practice
of. issuing clearances to organizations 'r nead of individuals was a weakness in
the clearance program.
Another type of clearance problem was noted during the review of closed work
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plans. The MWOR 1200?2 stated that "FWS-FV104 does not operate.
Found water
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- in air system. Trouble shoot and repair." Th'e inspectors found no evidence of
a clearance being set to perform the investigation described in the MWOR was
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available, thus the system had been breached without a proper clearance. The
licensee's failure to follow the requirements of Procedure ADM-0027 was an
apparent weakness in procedural adherence.
The licensee converted MWOR 120022 to MWO R120022 in accordance with
Procedure ADM-0028, " Maintenance Work Order." The work plan called for trouble-
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shooting the failed air-operated valve FWS-FV104. Although Step B and Step R of
the work plan provided itstructions for authorization and equipment modification
visor authorized the work.e was specified for the planned work. The shift super-
requirements, no clearanc
,
release without specifying a clearance be set. The
technicians that performed the maintenance set isolation conditions of the instru-
ment air supply to the solenoid operator and power supply to the solenoid operator
by using Procedure GMP-0042, Attachment 2, "Lifud Lead and Jumper Tag Sheet,"
rather than the Protection Tagging Procedure ADM-0027.
A similar circumstance of using GMP-0042 to set isolation conditions was noted
during performance of MM0 R134876. The work was authorized to be performed
without a clearance being set; the maintenance technicians used a " lifted lead"
tag (GMP-0042) to isolate the 110 psig air supply to the ASCO solenoid valve.
This is another example of the apparent violation (458/8904-02) for failure to
follow the provisions of Procedure ADM-0027.
It appeared to the inspectors that Procedure GMP-0042 was intended to support
instrument and electrical circuitry testing or alignments, not mechanical
maintenance activitiet such as cleaning air lines.
Contrary to the manner in
which the technicians used Procedure GMP-0D42, Procedure ADM-0027 clearly
stated in paragraph 5.21 that " fluid or gas systems that operate with
- temperatures greater than 200 F or pressures greater than 50 psig should be
isolated from the work area by two closed valves in series, with a tell-talu
vent or drain open between the isolation valves." These clearance conditions
were.not set for MWO R134876. The inspectors considered performance of
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maintenance on components without setting a protective tagging clearance in
3-
accordance with Procedure ADM-0027 a weakness in the licensee's program for
setting clearances.
On several occasions, the inspectors noted that maintenance technicians
arbitrarily did not perform a work plan step; they simply marked the step as
"N/A" with no explanation, nor did they note this action in the appropriate
section of the work order for subsequent approval by reviewing personnel.
Because of significantly increased lower bearing temperatures, MWO R122471 was
initiated to remove the normal service water pump motor (1SWP-PIC) so that the
vendor could overhaul it. The inspectors observed a mechanic mark one step
"N/A" without providing an explanation. The mechanic simply did not follow the
work plan. There was a sequence of steps in this work order that was critical
to the success of the maintenance activity; however, the maintenance
technicians failed to observe the protocol of signifying completion of each
step by initials before proceeding. The team was particularly concerned
because numerous hours had passed since the activities had been completed and a
different crew was' performing the succeeding evolutions. The inspectors also
noted that Procedure ADM-0028, " Maintenance Work Order," paragraph 5.12.24,
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stated to " follow the job plan in detail (not necessarily in sequential order
unless specified)'and initial the items as they are performed and reperformed."
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This provision was in conflict with Procedure ADM-0003, " Development, Control,
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.and Use of Procedures," paragraph 6.5.1, which stated that "unless otherwise
specified, steps in a-procedure shall be performed sequentially."
During conduct of-the electrical portion of the work plan, electricians failed
to follow the work plan with regard to refilling both bearing reservoirs with
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fresh 011 because it was not availabic.
Furthermore, when the electricians
,
found an alternative source of oil, they failed to sample uncontrolled oil before
adding itlto the motor reservoirs. Thus, licensee personnel did not follow the
requirements of paragraph 5.2.1 of Procedure ADM-0023, which stated that
- maintenance personnel shall adhere to instructions of approved work' documents."
"
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' The work' alan did not include the necessary torque data sheet for the motor
e
mounting bolts or coupling bolts.
Furthermore, no instructions were provided
4
in the work plan for a jacking device that would permit turning the very large
service water pump / motor assembly while performing run-out checks. During the
conduct of MWO R131564, which started on October 2, 1989, the work had to be
stopped because the coupling on Sump Pump DFT-P1B was sheared. The licensee
advised the inspectors that the planner--after receiving MWO R131564 on
August-16,1989--had inspected the turbine building floor drain sump pumps
.
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before writing the job plan on August 21, 1989. There had been no evidence of
a pump coupling problem at that time. This indicated that if enough time
elapsed between planning and accomplishment, the circumstances under which the
original planning occurred could change.
Procedure ADM-0028, " Maintenance Work
Order," paragraph 5.2, indicated that "the Discipline Supervisor shall review
the MWOR and when necessary inspect the problem (s), to validate the request."
r
There were no specific instructions.about a job-site walkdown before planning
the work or consideration about what to do if considerable time elapses before
the job plan is worked.
i
The inspectors reviewed the training received by the planners in an effort to
determine potential causes for some of these problems. The licensee considered
three courses fundamental to the qualification of a planner. However, none of
the nine planners had completed all three courses, which indicated that
,
implementation of the training was inadequate.
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The NRC inspectors observed 180 technicians performing a semi-annual
surveillance (STP 503-4205) of the control rod block source range monitor. The
procedure defined the purpose, plant mode, applicability, and frequency;
required equipment; precautions and limitations, and prerequisites. The
procedure was easy to follow and the technicians demonstrated an understanding
and familiarity with the contents of the procedure and the system.
Communications between the two technicians, using a reader / performer technique,
were excellent. All measuring and test equipment (M&TE) was in calibration and
in good condition. One minor procedure deficiency and one technique deficiency
were noted. One procedure step was duplicated and appeared unnecessary. The
technicians submitted a comment sheet to remcve one of the duplicate
steps (7.1.83.5 or 7.1.83.11). The technicians used a homemade device to hold
the push-button down to disarm an alarm.
Use of an unauthorized device without
appropriate procedural controls was considered a weakness.
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- The inspectors observed 1&C technicians perform selected portions of
MW0s R134933 and R124038.- Both MW0s were to evaluate and troubleshoot area
high temperature alarms associated with the TAMARIS temperature monitoring
system to determine that the indications and alarms were consistent with the
ambient temperatures at the sensor locations. Troubleshooting by I&C personnel
was-performed with assistance from field engineering. During the pre-work
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review of the work plan ILC technicians and the field engineer noted that the
incorrect loop calibration report was listed, and the work plan limited the
o
ability to perform actual troubleshooting. An incorrect assumption that work
e
was to be doni-in the iodine filter room resulted in the involvement of a
health physics technician. Although the technician properly hung the lifted
A,
lead tags to the thermocouple wires and disconnected the leads, he proceeded
with the work for several minutes before the second technician required him to
document the lifted leads on the lifted iced tag sheet. The inspector
_ concluded that'the failure to document lifted leads in a timely manner was a
poor work practice.
Field engineering and health physics support of these
maintenance activities was good.
4
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-The conduct of these MW0s, collectively, showed a weakness in the licensee's
program for maintenance personnel to follow procedure; a weakness in the job
planning because the planner failed to specify the necessity for step
s
sequencing, failed to include the necessary data, and made incorrect
assumptions; and a program weakness because Procedure ADM-00P8 provided an
alternative to compliance with necessary procedural 4 tail when it should not
and when-it is in conflict with Procedure ADM-0003.
In addition,
implementation of training for planners was inadequate.
Maintenance of Equipment Records and History' Area
4
-Although the licensee had a computerized and sortable record of equiament.
history, it was difficult to use without a master equipment list. T1e system
utilized a " mark" number to identify the ap111 cable system designation.
Several components were listed under more tian one mark number. The data base
appeared to be updated on a regular basis and centained sufficient data to
produce useful information, however, there was no evidence of the inclusion of
repair time. The inspector determined from discussions with licensee personnel
that there was an effort under way to generate a master equipment list, but
because of the fiscal restraints, it-was a low priority item.
The inspectors reviewed the equipment history for several components in the
'
standby service water (SSW) system and the residual heat removal system. Two
motor-operated valves in the SSW system had no equipment history records,
several components had entries under more than one mark number, and the RHR
pump entries were not under the mark number shown on the flow diagrams or in
the operating procedure. The inspectors learned that there were three
numbering systems in use; there was no independent verification of the
equipment history data; and there was no cross-reference of like component
identifiers between systems. Because each system had its own identification
prefix, component failure trending would be difficult, and unless the multiple
mark number entries were known, trending of system components would be
difficult. Thus, without correction of these problems, the equipment history
data was of limited value.
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-Work Prioritization Area and Backloo Controls
The work prioritization listing was maintained in a computerized data base with
. items separated in two categories, operating and outage. These categories were
- then prioritized one through five (one being the highest priority).
The work priority method appeared to encompass all outstanding work requests.
The
multiple work request entries would suggest that periodic screening of entries
was in order. 'Although PRA is not used in assigning priorities, the priorities
were assigned.in an order that indicated safety and effect of balance of plant
items on safety were considered.
Although the start date for priority two items generally exceeded the recommended
start time of 7 days, there were no safety issues identified with the delayed
start times. The prioritization of work was satisfactory but could be improved.
The inspectors examined the backlog data, which indicated between 800 to 1000
items in the_ backlogimost of which were low priority. The mechanical and
electrical work orders had decreased over the last year, and the number of
overdue MW0s had been significantly redt.ced in the last year. Licensee
management indicated that the present backlog and work-off rate were at a
desirable level. The team considered the licensee's control of the maintenance
backlog a defined strength _in the maintenance process.
Completed Work Control Documents
An adequate program was in place for the review of completed work that had been
documented, but the' inspectors identified discrepancies that had been
overlooked during the licensee's review process.
Hydrostatic testing of-the unit cooler following weld repair of the header was
required in accordance with MWO R112280.
However, the hydrostatic test was not
. performed before returning the unit cooler to service; instead, specific steps
in the job plan were marked "H/A" by maintenance personnel.
The condition was first identified by the field engineering codes and standards
group during a review of the closed MWO and was subsequently documented in
Condition Report 88-0757. After an investigation, the licensee concluded that
a hydrostatic test that meets ASME Code requirements had been performed.
Ncnetheless, the intpectors were concerned that because the codes and standards
group did not review MW0s until after they were closed out, a failure to
perform a required step, such as the weld repair hydrostatic test, could remain
undetected for months.
Closed work plan documents, such as MWO R118513, often contained steps that had
not been performed, but no explanatory coments were provided, nor were
approved changes made to the document.
In addition, Step BB of MWO R118513
required operations to be notified of completed maintenance to ensure that any
limiting conditions for operation (LCO) associated with these MWO were closed.
The step was marked "M/A" although LC0 TR89-010 was distinctly stamped on the
front of the MWO as effective and applicable. MWO R123150 and hWO R05633 also
hed discrepancies with regard to the LC0 stamp.
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An inspection and retorque of yoke and bonnet bolts on the residual heat
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removal (RHR) ,"A" test return valve (IE12*MOVF024A), was required in accordance
withMWO56253(PromptMMO).
The MWO functional / operability testing section and Step 6 of the work plan
s
!
required a check for a bent valve stem during stroke testing of the valve; an
entry was made that the step was "not performed." No explanation was provided
for not accomplishing the step.
Failing to follow the work plan was another
example of the apparent violation (458/8904-02) of the licensee's adherence to
procedures.
In addition, the inspectors noted that paragraph 5.14.2 of Procedure ADM-0028,
" Maintenance Work Order," required the maintenance supervisor or designee
during his post-naintenance review to " ensure all fields of the MWO are
e
correctly filled out and that all blanks have been N/A'd." The team perceived
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this instruction as counter-productive to the intent of the review. Revising
this instruction would ensure the intended review action was accomplished.
Closed work plan documents often-contained indications of abnormal problems
that were encountered during the maintenance activity. However, no evidence of
an evaluation of the abnormality existed, and apparently the licensee took no
,
further action on the described problem.
MWO R118513, MWO R120022, and MWO R118194 have examples of craft technicians
not recording problems that were encountered during maintenance activities in
the proper location of the work sheet. To be-consistent with the procedural
requirements of Procedure ADM-0028, the problems encountered are recorded and
that action is-initiated to resolve the problems.
. Inasmuch as craft technicians failed to comply with these requirements, the
inspectors considered this to be a weakness in the licensee's program.
,
Closed work plan documents sometimes contained indications of improper work
practices by craft technicians in which the quality of the installed components
was not. maintained, production was adversely affected, and rework was.
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increased.
During performance of MWO R123150, the valve actuator was removed to permit
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extensive rework of the valve stem, seat, and packing. However, the actuator
was-damaged during valve repair and the actuator ceuld not be used during
reassembly. The inspectors noted that the subject of component protection
during maintenance activities was not addressed in the maintenance procedure.
s
This was considered a program weakness.
,
During performance of MWO R133582, the shaft assembly was installed in the
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pump housing and the housing bolts were tightened, leaving the steps to
set impeller clearance and to make final adjustments of gland and seal to
another shift. However. while attempting to set the impeller clearance,
the subsequent shift noted that the impeller was loose on the shaft even
though the assembly steps had been signed off by the previous shift. The
pump had to be disassembled and the impeller tightened on the pump shaft
before the remaining steps could be completed.
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During performance of tiWO R134408, the as-found torque switch settings
-were 1.5 for the opened and closed positions. The recommended torque
switchsettings_(CMP-1253,AppendixA,TabulationofM0VData)were
1.75 minimum /2 maximum. The inspectors noted in Procedure CHP-1253,
Section 8.5.3, that the torque switch setting could be set-below the
.
recomended minimum value if (1) actual valve stem thrust data is
available that indicates the need to lower the torque switch setting, and
(2) design / field engineering has reviewed the thrust data'and approves the
lesser torque switch setting. The inspectors reviewed previous work
packages for the 1E12*MOVF024A valve where electrical vork may have caused
such an adjustment and approval to occur; no documented evidence was
.
available to indicate that the lower-than-recommended setting had been
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. approved in accordance with the CMP-1253 procedure. This is an unresolved
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issue pending further licensee and NRC investigation and resolution
(458/8904-03). The inspectors also considered it to be a program weakness
that there was no ready method available to indicate when such adjustments
may:have been appropriate in previous maintenance actions.
During its review of closed work packages that preceded the above
described problem with the torque switch, the inspectors were unable to
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determine when, how, or why previous closecut inspections performed in
accordance with Procedure CMP-1253 failed to detect the potential problem.
'
The licensee issued MWO R122427 to investigate and repair mechanical
"
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deficiencies noted under 11W0 R134408. The inspectors reviewed the
referenced procedure CMP-9190, " Valve Lapping," and noted that
Section 8.0, " Procedure," required steps-to be performed that were
.
'different from those recorded by the mechanic. Failure of the mechanic ~to
- follow the method clearly specified in the procedure was considered a
,,
program weakness.
Closed work plan documents sometimes contained incorrect or incomplete data
entries that the inspectors observed were inconsistent with the requirements of
Procedure ADM-0028.
For example the PM task sheet for MWO P533993 had the
s1
wrong component mark number, thus the clearance request for setting isolation
conditions generated confusion and delayed the commencement of the maintenance
activity. _ The computer data base from which the PM task sheet was prepared had
the incorrect mark number. The inspectors noted that the HPCS standard
operating procedure also contained an-incorrect mark number.
In addition,
MWO R134408 carried an incorrect mark nunber because the MWOR was prepared with
the wrong component mark number.
Inconsistencies in component nark numbers
appeared to be the result of the licensee not having a complete master
equipment list, which was considered a progran weakness. Such errors could
clso contribute to poor naintenance history if left uncorrected.
Closed work plan documents were often noted to lack sufficient, specific work
plan steps that would permit the craft technicians to explicitly accomplish
their work:
No procedures or vendur technical manuals were referenced by 11WO 56253 to
assist with the accomplishment of certain steps.
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The installation of Oatis Signature test equipment was called for by
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MWO R134408. However, wiring diagrams were neither referenced nor included.
Although MWO R123150 referenced procedures and the vendor's manual, it was
not specific. The vendor's manual contained many sections that were not
directly applicable to the task, and applicable sections of referenced
procedures were seldom specified in any of the work plans.
In general,
the level of detail was poor.
'
The practice of not referencing specific sections of technical manuals or
procedures and the= lack of a definitive program was inconsistent with the
requirements of ANSI N18.7-1976, " Administrative Controls and Quality Assurance
for the Operational Phase of Nuclear Power Plants," Section 5.3.5 (4),
" Supporting Maintenance Documents." This poor practice was considered a weakness.
.
[
.The inspectors reviewed selected liW0s that contained LCO-related conditions.
'
Most of these NW0s included work plan steps that required the maintenance
foreman to-ensure that the LC0 was cleared when the work completed (for example,
MWO R123150, Step T, and MWO R117861, Step 5).
However, the inspectors found
this incongruous because the maintenance technicians cannot ensure the LC0 is
cleared when work is complete; therefore, they should not be tasked with the
responsibility.
It appeared to the inspectors that at the time the shift
- supervisor / control operator foreman completes his review of the MWO, following)the
he should be:specifically tasked with the review of outstanding LCOs against the
MWO and take proper; administrative action.
The following example illustrates a conflict between two procedures, which
could have led _to the shift supervisor not being aware of plant status. The
licensee performed MWO R134856 to install a filter'in the air supply line to
ASCO Solenoid Valve IHVR* SOY 10B. 'To deenergized the solenoid for overhaul,
the technicians used the loop calibration report diagram (1.THVR.038) to
determine the point at which the power leads should have lifted and decided to
lift leads in the control room termination cabinet. When one of these leads
was lifted, five additional air dampers unexpectedly changed position (CR 89-1058).
When the NRC inspector reviewed the MW0, he found that the " problems encounter /
remarks" section of the work performed section was inappropriately narked N/A
and the shift supervisor approval block was marked N/A by the field engineer.
Procedure ENG 3-006, " Modification Request Control Plan," Section 6.9.5,
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rovided the field engineer authority to sign the MWO for the shift supervisor
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p(for MW0s initiated to perform work under a modification request).
Procedure ADM 0028 for control of Sections 5.16.1 and 5.16.2 of the MWO required
the shift supervisor / control operator foreman to review MW0s to insure applicable
retests were performed and to complete applicable portions of the sign off
section of the NW0.
!
On September 30, 1989, while conducting Procedure STP 051-0201, "RPS-Main Steam
'
Line Isolation Valve Closure Monthly ChFunct," an unexpected reactor scram
occurred. The licensee's investigation (CR 89-1070) showed that the contacts
on Test Switch C71-56D, Channel D, were open rather than in their normally closed
position. This test switch, General Electric (GE) Model CR 2940, is a three-
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position key-operated switch, the key can only be removed when the switch is in
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Lthe normal position. The key was removed and the switch-appeared to be in the
! normal position; however, the switch was actually about 1/32 of an inch off the
,
normal position and the contacts were open. The last known operation of the
Channel D test switch occurred on September 2, 1989, during the previous monthly
check of Procedure STP 051-0201. The Channel D test switch was replaced and the
plant returned to power operations.- At least one switch from spares exhibited
the same fault:
the key could be removed before the contacts were in the desired
position. On October 3, 1989, all spare GE CR 2940 switches were evaluated, and
8 of 23 failed. The licensee's root-cause cvaluation of the switch failure was
in progress at the end of this inspection. Condition Report 89-1079, dated
October 3, 1989, identified 24 GE Model CR 2940 type switches installed in the
control room. The licensee's engineering staff verified that the switch contact
of interest (three and four) for all 24 installed switches were in the proper
position. The facility review committee authorized restert, in part, on the basis
of GE design philosophy that includes a light or an annunciator when switches
are used for bypass. The inspectors were concerned that this decision was based
F
on a design philosophy rather than rigorous engineering evaluation.
During the troubleshooting efforts of the reactor scram of September 30, 1989, a
field engineer noted two schematic diagrams for the reactor protection system
(508 series) were missing from the control room set of control prints.
He
informed the shift supervisor at that time. On October 2, 1989, the two schematics
were.still missing. Discussion with the shift supervisor revealed that he had
audited the 508 series of diagrams and that the missing prints were being replaced
that afternoon. Procedure ADM 0005, " Station Document Control," Section 4.5,
assigns responsibilities for maintaining control over documents within their
respective satellite station to satellite station custodians. The compliance
department committed to a 100 percent audit of the control room prints.
3.2- plant Maintenance Organization
3.2.1 Scope
The objective of this part of the inspection was to determine the effectiveness
and extent of control exercised by the plant maintenance organization for
maintenance activities in the mechanical, electrical, and instrumentation and
control areas. Management oversight and control of contracted maintenance and
handling of deficiency identification and control methads also were evaluated,
as were maintenance trending and support interfaces.
3.2.2 Conclusions
Although the licensee had good programs in place and was achieving good results
'in' implementing the programs in the electrical and I&C disciplines, some
improvement in the mechanical area was required. The deficiency reporting
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program was readily available and used by plant personnel in an adequate
manner. Maintenance trer: ding programs were not developed and implemented.
Support interfaces were adequate, but required some improvement'in some areas.
While contracted maintenance appeared limited (almost exclusively to personnel
services) the licensee's controls appeared adequate for ensuring that contract
personnel were properly trained and supervised while working on site.
However,
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management attention was needed to ensure that contract work was adequately
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controlled and documented. The lack of an objective verification of education
and experience claims by contracted personnel was considered a weakness.
The . licensee's system for identification and control of deficiencies was well
,
documented and the tracking and accountability of the deficiencies were effective.
The program was availabic to, and frequently used by, plant-personnel. However,
the length of time some quality assurance finding reports have remained open
a1peared to be excessive and was considered a weakness in the implementation of
'tle program..
Support for direct maintenance activities by engineering, quality control,
'
. operations, safety, health physics, and supply departments was demonstrated to
be~ adequate.
3.2.3 Findings
Electrical Maintenance Organization
The inspector considered the technical ability, attitude, and conscious commitment
of the electrical maintenance organization personnel a strength. They did an
excellent job of following procedures and documenting the results.
The inspector observed that the electrical maintenance organization adhered to an
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orderly process of identifying electrical maintenance needs. Work order priority
was recognized and progressed accordingly. Supervisors were kept informed of-
progress and any unusual delays or problems. ~ Craft personnel. documented and
instituted action to correct deficiencies noted.during their performance of work
activities. -The work orders contained detailed descriptions of work performed,
.
documentation of deficiencies, corrective actions instituted, and other actions
important to the work activity.
System integrity was maintained through proceduralized tagging of lifted leads,
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jumpers, and removed equipment during maintenance activities.
Electrical foremen
interfaced with the craft on the job site and monitored maintenance activities.
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z(he inspector reviewed the work package to upgrade power line conditionsISCI-XRC1
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The work package contained QC. hold points to verify qualified parts were
controlled. The testing was done with a marked-up copy of.a startup procedure.
Although this procedure was narked up extensively, it did not provide the
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require acceptance criteria for upgrade.
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Qualif.ication status was maintained current through the training department and
job assignments were made according to each individual's qualifications and needs.
The work order briefing sheets contained the signature of the craft employees
assigned along with that of the foreman, who assures that the employees assigned
to perform.the work are properly qualified. This provides an auditable system
to detect qualification discrepancies during maintenance activities. Procedures
used with work activities are checked out to an individual and dated, which provides
an auditable trail to ensure that the correct revision of the procedure is used.
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When H&TE personnel issued maintenance tools, they checked to see that they
were calibrated and noted this in the work documents.
The inspector observed several controls and work practices to ensure that
maintenance activities returned the systems to their normal operating
configurations. The electrical group adhered closely to work order instructions,
which required the proper tagging of components. They exhibited excellent
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housekeeping work practices during and at the completion of work activities.
The work activities were well documented to provide accountability of work
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' performance. Work documents were promptly and adequately reviewed to ensure
all requirements of the work activity had been properly accomplished and
acceptable, or that exceptions were properly identified. All four electrical
maintenance crews and associated foremen exhibited excellent work practices and
demonstrated knowledge in the areas observed. Although not always equipped
with modern equipment, such as breaker lifting and testing devices, the quality
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of-their work was not affected. The electrical maintenance group communicated
well with other organizational groups to coordinate their work activities.
Mechanical Maintenance Organization
Station procedures and policies controlled the maintenance activities of the
mechanical discipline and provided a generally adequate methodology. However,
as discussed in Section 3.1.3, specific areas required further licensee
attention. Although the mechanical group seemed well aware of requirements
affecting the performance of their trade, errors in performance did occur.
Nonetheless, the mechanical group demonstrated a strict adherence to safe
practices in the operation of vehicles and a good knowledge of special chemical
(ontrol permits. They were able to reference appropriate guidance to clarify
questions. Craft-personnel. demonstrated a clear understanding of what to do
when work plans could not be complied with. The correct use of spare parts was
clearly understood. The mechanical technicians appeared to be highly motivated
toward performing their tasks correctly and showed a willingness to adhere to
procedure.
In contrast, however, on one occasion, the torque wrench that would
be used to tighten cap nuts on a check valve was dropped with no apparent
regard for the possible upset in wrench calibration.
(It was not able to be
determined whether the wrench would have been subsequently used since the
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maintenance was interrupted.)
First line supervisory attention was readily apparent on the job, with craft
level knowledge noted to be very good.
Supervisors routinely demonstrated
their responsibilities to assign properly qualified personnel and to conduct
proper prejob briefings.- However, as noted elsewhere in this report, attention
to critical administrative detail was noted to be lacking. A peer evaluation
-progran for the mechanical discipline was implemented during the inspection
period to increase monitoring activities of craft performance.
If improved
performance does not result from this v:tivity, the licensee should consider a
higher level of management involvement in on-the-job site evaluation.
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Instrumentation and Control (I&C) Maintenance
The I&C maintenance activities were controlled by station procedures and
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policies. The MWORs were documented and processed for corrective maintenance
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work'
Approved MWOPs were routed to the work planning department for development
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of an MWO package. The MWO was routed to the I&C supervisor who assigned a foreman
to accomplish the work. The foreman assigned the work on the basis of the training
~ and experience levels of their crews.
Each foreman briefed the work crew and
documented the briefing in the work package. The crew assembled the necessary
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. tools, spare parts, and test equipment, obtained the required clearances and work
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release, and performed the work in accordance with the MWO. Procedure ADM 0028,
' Maintenance Work Order," details the responsibilities and processing requirement
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for"the accomplishment of maintenance activities. Most of the I&C work packages
contained reference to a vendor manual and a loop calibration report (LCR),
N . , ';
Vendor technical documents and information were maintained current by the
engineering department, in accordance with the requirements of Procedure EDP-AA-65,
" Review and Processing of Vendor Technical Information" and RBNP 032, " Processing
of Vendor Technical-Information." These procedures require all vendor technical
information received to be routed to the engineering department for review and
approval before being used during maintenance activities. LCRs were prepared by
the design engineering department. Use of LCRs by I&C technicians was governed
by Procedure liCP-4001, " Loop Calibration." Configuration controls were detailed
in Procedure GMP-0042, " Circuit Testing and Lifted Leads and Jumpers."
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The IAC technicians demonstrated the knowledge and understanding of procedures,
willingness to adhere to procedures, and the skills necessary to accomplish
maintenance and repair at the station. The inspectors noted that I&C foremen
routinely went into the field to check the progress of_ work crews. The work
crew documented its work in the MWO. This description of work consistently was
detailed and complete. The inspectors considered the work performed section of
the MW0s a strength.
.The program and implementation process of controlling maintenance activities in
the I&C department was adequate. As noted in the previous section, the inspectors
were concerned about tile errors contained in some work plans. The inspectors
learned from I&C planners that a recent loss of one planner had placed an excessive
burden on the remaining planners.
Contracted Maintenance
During the review of completed MWO P530212 to perforn Procedure PMP 1245,
" Preventive Maintenance of the Emergency Diesel Generators EGIA and EG18," the
inspector questioned the licensee as to whether certain data met the accQi.ance
criteria of Procedure PMP-1245 for Diesel Generator EG1B. The licensee
subsequently reviewed the data and declared the diesel generator inoperable and
entered the actions of Technical Specification 3.8.1.1.
The data reviewed for
Procedure PMP 1245 had been transferred from other documents and procedures
~
that the licensee had performed under contract work. The licensee subsequently
decided that the acceptance criteria of Procedure PMP 1245 required changes.
.The licensee's failure to review properly the completed Procedure PHP 1245 data
and correct the unacceptable data reflects a failure to control work activities.
Essentially all contracted maintenance was subject to, and worked in accordance
with, the licensee's program, as opposed to working under the contractor's
program approved by the licensee. Most contracted personnel were used to
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augment the existing plant staff during outages or major modifications. One
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recent exception was a contract with Cooper-Industries for maintenance on the
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emergency diesel generators. - The contract specified the scope of work, the
qualifications of the personnel, and the required experience,
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Procedure MSP-0028. " Qualification of Contract Maintenance Personnel,"
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Revision 2, was one of several procedures that provided requirements for
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training and control of contracted personnel. This procedure specified minimum
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experience and education levels. The Cooper Industries contract contained
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these procedural requirements, which included site-specific training structured
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to-the discipline involved.
In addition to general site access training,
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contracted _ personnel and their work was monitored by licensee management, and
all work performed was under direct supervision or done with qualified
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personnel.
While the- control'and training of contracted personnel af ter they arrived on
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site was adequately addressed, the preemployment or preaward verification of-
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personnel appeared to be lacking. Even though there were procedural and
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contractua.1 requirements concerning education and experience of personnel,
there were no procedural requirements or evidence that objective _ verification
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of education and experience was being acconplished.
'The inspectors reviewed the control of contract personnel during the secnnd
refueling outage. . Several examples were identified by the licensee and/or NRC
inspectors that indicated that control over contract personnel was not adequate
to prevent significant violations of the clearance program or to control the
performance of maintenance activities.
Deficiency Identification und Control Area Methods
There were four methods of documenting deficiencies:
the condition report, the
quality assurance findings report (QAFR), corrective action report, and stop-work
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order. _ Each of these methods was trended and each deficiency was subjected to
a root-cause analysis. Other less formal means of documenting problems would
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be the internal " audit concerns," which were tracked and closed but not
trended.
The most frequently used methods for documenting deficiencies were the
condition report ind the QAFR. The QAFR was the principal method used to
document internal audit findings related to programnatic deficiencies or other
p oblems not related to hardware. The condition report was used to document
all hardware deficiencies and programmatic or software problems (in some cases).
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The system for accountability.and the tracking of condition reports and 0AFRs
appeared well established and effectively implemented. Since condition reports
related primarily to hardware, their closure was often dependent on maintenance
and outage schedules. -On the other hand, QAFRs, which related to programmatic
issues, should have been closed promptly; however, as of October 4,1989, there were
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69 0AFRs that were open. Ore of these QAFRs had been open 1140 days and six
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others had been open more than a year. The inspectors considered this a
program weakness.
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Support Interfaces
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On-the basis of direct observation and discussion with shop supervisors and
craft personnel, the inspectors determined that support of direct maintenance
activities was fully implemented. Support engineers and personnel willingly
assisted in maintenance and troubleshooting efforts. Support personnel demon-
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strated an excellent attitude and commitment to the maintenance of plant
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systems and equipment.
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One good example of support personnel involvement was during the QC coverage
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provided for MWO R134876. During the work on this MW0, the QC inspector noted
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the need for additional QC coverage for other work in progress for the
1A diesel generator. He arranged for the needed coverage and work proceeded
with very-little delay.
In. addition, the electrical system engineers provided
full inspection coverage and assistance during the 1A diesel generator system
outage,
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Another was I&C's implementation of a program to support the chemistry depart-
ment. One technician is assigned to provide. direct interface with the
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chemistry department ~ to improve the reliability of analytic instrumentation.
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3.3 Maintenance Facilities and Materials Contro_1
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3.3.1- Scope
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The objective of this part of the inspection was to assess the maintenance
facilities and controls over equipment, tools, and materials accessibility to
determine how well these elements support plant maintenance and repair work.
Implementation of these controls was not inspected.
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3.3.2 Conclusions
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The licensee's maintenance facilities were of excellent quality and located so
that they were easily accessible.for the support of maintenance. The program-
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for material control was found to be well documented, covering all aspects of
receiving, handling, and storage of material. Although the measuring and. test
equipment programs and implementation were considered adequate, an inventory
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control system was needed to strengthen the maintenance tool and equipment
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area, as well as a method to enhance the experience icvel of issue room
attendants.
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3.3.3
Findings
Maintenance Facilities and Equipment
The inspectors found the arrangement and location of the work shops adequate to
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support maintenance and repair work. The primary work shops, for example,
machine, I&C, and electrical, were located in the service building. The
inspectors found that the. cold and hot machine shops were particularly well
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equipped to support any conceivable task the licensee would choose to perform
in-house. Contaminated equipment awaiting shipment in the hot machine shop
appeared minimal.
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The array of machinery far exceeded the machinist staffing available to take
advantage of the equipment. The areas were well maintained with adequate laydown
areas for larger components, and an area for personal tools was available to each
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mechanic. 'A highly motivating benefit for each maintenance technician was the
company policy of providing a complete set of personal tools to the technician,
with lost or damaged tools being provided from company stock.
Maintenance manager and supervisor offices were situated close to the shop areas,
providing reedy access to the work spaces for management and supervisory personnel.
The' tool and M&TE issue room was located in the T-tunnei between the turbine
building,and switchgear room.
Contaminated equipment was separated by a cyclone -
fence within the issue facility. The issue facility location supported outage
work when access to the plant was through the T-tunnel; however, this location
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was somewhat inconvenient during routine operations when access to the-plant
through'the T-tunnel was restricted by the health physics department.
Materials Control
The 13 naterials handling procedures provided well-documented controls and
direction for all aspects of receiving, storage, handling, and control of materials.
These procedures were supplemented by Procedure GitP-0041, " Storage and Maintenance
of Material / Equipment," Revision 4; Procedure RBNP-045, " Materials flanagement,"
Revision 0; and Procedure QCI-3.0, " Receiving-Inspection," Revision 10.
The site had three warehouses. The principal warehouse, from which all site
material was received and distributed, was designated "B."
Warehouse "A" was
basically a long-term storage facility. A third facility, designated "RB2,"
was'*n i.he protected area and was primarily used to store and issue consumables
and as a staging area for long-ter:n activities.
The inspector observed that Warehouse "B" was clean and orderly and had a
temperature-and-humidity-controlled area for storing sensitive components and
material. Nonconforming material (i.e., material with inadequate
documentation,= or material awaiting disposition) was segregated in a locked,
fenced area.
Maintenance Tool and Eauipment Control
The issue room attendants controlled the tools and ecuipment necessary to
support maintenance activities (other than normal hand tools). Each issue was
logged by unique identification number, date checked out, and date returned;
checkout was limited to one shift unless specifically authorized by maintenance
supervisors. Personnel checking out tools or equipment were required to be on
a list of approved personnel.
Issue room attendants were classified as utility workers and were entry level
workers who were normally promoted (by seniority), if qualified, to an
appropriate open position as they became available. The result of such
promotions kept the experience level of issue attendants low--currently less
than one year in the job. The licensee had recognized the low experience level
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of' issue room ~ attendants as a program weakness and was negotiating with union
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representatives to establish a permanent position for an issue room attendant.
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The' inspectors believed the low-experience level of the issue room attendants
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could have contributed to the improper issue of M&TE dial indicator, DIN 130A,
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on September 17, 1989.
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The issue room supervisor had implemented a program to improve performance of
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the issue room attendants. The attendants demonstrated an understanding of
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issue control pro edures and a conscientious attitude toward properly
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implementing procedures.
The. team inspected the tool issue and storage facilities and found them to be
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very clean and well maintained. Three locations were used in addition to the
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main'issuepointforstorageofbackupsuppliesofseldom-useditems(suchas
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refueling only items)..
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Although current inventories were available for the storage locations, no
current, correct inventory was available for the main storage / issue point for
non-M&TE items. The inspector noted that an approximate 10 percent
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nonavailability rate was being recorded by the licensee on non-M&TE issue
requests, most'of which were common items. The inspectors noted that in
addition _ to-not having.an inventory of. items, the licensee had not established
a system of minimum / maximum quantities of items, nor defined a system to
reorder when reaching some predetermined quantity of an item.
Inventory
control of non-M&TE tools was mostly reactive to requests for tools that could
not be fulfilled, rather than proactive in the sense of determining tool needs
for tasks expected to be accomplished in the future.
Nonetheless, inspectors
did observe proactive thinking with regard to a major work item to be undertaken
in a forthcoming outage--special tools were being identified and procured well
-in advance of the planned maintenance activity.
In addition, the MATE supervisor
.had implemented a survey of issue room transactions to determine the adequacy
of the quantity and quality of tools and equipment. Although this program was
not formalized,-the inspectors considered it a strength to improve the material
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and equipment control system.
Control and Calibration of Measuring and Test Eouipment
Procedure ADM 0029, " Control of Measuring and Test Equipment," established the
facilities M&TE program. The procedure details the issue, recall, storage, and
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segregation of special- or limited-use M&TE. This procedure provided
instructions for placing damaged equipment out of service and for resolving the
use of out-of-tolerance equipment in the field.
Each piece of M&TE had a "use card" that was used to record the date out, name
of person checking out, department head authorization, date checked in, name of
person checking in, tracking card used, initials of the clerk checking in the
device, the device identification number, and the calibration due date.
Tracking cards were filled out by the equipment user for identification of
usage in case an out-of-tolerance condition was detected.
Recall of M&TE
approaching the calibration duc date was controlled by computer sort and manual
review of use cards by issue room attendants; this process was conducted twice
weekly.
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Procedure ADM 0029 permited issue room attendants to replace missing or defaced
M&TE calibration labels after verifying by document review that the device was
< in calibration. The M&TE supervisor indicated that this weakness may have
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contributed to the improper issuance of.a piece of test equipment, DIM 130A
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.(discussed below), and that the strengthening of the procedure in this area
would be accomplished;
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The M&TE storage was~consid"ernd adequate. However, out-of-calibration and
out-of-service M&TE items were not. physically separated for storage from the
ready-for-issue racks and, labeling did not clearly identify the segregated
storage racks.
In addition to the inappropriate storage of a dial indicator in
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a zip-lock storage bag (discussed in some detail below), some items of test
equipment (notably, circuit extender cards) were stored in a jumbled mess.
Damage to an extender card would probably not be detected until used for-
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troubleshooting-or equipment calibration, in which case it would then delay
work.
Th'e MWO 122471 for service water motor overhaul and pump repack contained
information on the details continuation sheet dated September 17, 1989, that
M&TE Dial Indicator DIM 130A was issued for field use after its calibration due
date. The licensee did recheck the dimensions with DIM 121A; which was in
. calibration. During inspection of the 11&TE issue room on September 20, 1989,
the inspectors found DIM 130A located in the ready-for-issue section of the
M&TE room. Dial Indicator DIM 130A was stored in a plastic zip-lock bag, a
calibration label attached to the bag indicated the date of calibration was
-April 26, 1989, and the due date was July-26, 1989. This did not correspond
with the M&TE master list update, which stated that the dial indicator was
received and calibrated by the calibration facility on April 12, 1989. A
calibration due date of October 12, 1989,- was assigned and the dial indicator
was returned to the M&TE issue facility on April 17, 1989. The M&TE use log
indicated DIM 130A was used several times during April and May 1989, and,the
tracking' card, dated May 5, 1989, indicated the calibration due date for
. DIM 130A was July 26, 1989. This date conflicts with the master list and the
M&TE use log.
In addition, tb.e M&TE use log indicated that on September 17,
1989, DIM 130A was issued to mechanical maintenance on two occasions.
The inspectors concluded DIN 130A was issued on September 17, 1989, in
violation of Procedure ADM 0029, " Control of Measuring and Test Equipment,"
because the calibration due date was not verified. Additionally, the return of
DIM 130A to the ready-to-issue section of the issue room was considered a poor
practice. Procedure ADM 0029 required the issue room attendant to check
returned H&TE items for missing or defaced calibration labels. During this
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check the attendant should have noted the expired calibration due date and
implemented an out-of-service report. The storage of sensitive M&TE items in
unprotected zip-lock' bags was considered inappropriate.
Twenty M&TE items scheduled for calibration were checked by the inspector to
make sure they were properly removed from service and segregated.
Ho
discrepancies were noted. During conduct of activities in the calibration
laboratory, the inspectors noted that all equipment in use was in calibration,
personnel appeared knowledgeable of procedures, and the facility temperature
cnd humidity were properly controlled and monitored.
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3;4, Personnel Control
.3.4.1
Scope
The objective of this part of the inspection was to determine the extent to
which personnel are trained and qualified to perform maintenance activities,
~ including staffing, training, and current personnel control status.
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'3.4.2
, Conclusions
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The licensee's human resources policies had been implemented and established
effective staffing controls.- However, the inspectors noted that projected
-staffing-levels could negatively affect both maintenance and the technical
support areas..
The licensee's supervisor / worker ratics appeared sufficient to effectively
maintain control and coordination of work activities although supervision of
maintenance personnel with regard to procedural adherence needed improvement,
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sThe licensee, with few exceptions, pursued an aggressive training and qualification
program with its maintenance personnel.. Additional attention by management is
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needed to ensure the maintenance planners are adequately trained to produce quality
- work packages. Furthermore, systems engineers needed specific dedicated systems
- training.
- 3.4.3' Findings
The licensee's training and qualification program had been INP0 accredited and
appeared well documented. The licensee has initiated formalized training for
plant management.
However, it was noted that not all maintenance planners have-
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received the basic boiling-water reactor series training and, in some instances,
had not- received maintenance _ work order administr6 f on training. Furthermore,
the systems engineers have not received specific dedicated systems training.
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The facility's organization chart was current.
Plant management monitored
staffing levels and trended relevant data, including reasons for terminations.
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Plant staffing levels for 1989 were about 100 persons below the' full plant
- staffing complement. Plant performance data showed that attrition rates in the
.I&C, radiological protection, chemistry, and mechanical maintenance disciplines
-had exceeded the plant's desired goals. Furthermore, the engineering staff will
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be reduced by 14 persons by December 1990 with only 6 planned requisitions.
The. inspectors were concerned about the potential impact of the reduction in
the systems engineers' workloads and the effectiveness of recently initiated
-programs.
_
Procedure MSP-0009, " Qualification of Maintenance Personnel," governed the
qualification of craft maintenance personnel. This procedure provided for a
two-part training program for specific skills in each of the disciplines. A
computerized training matrix was maintained to indicate each maintenance
technician's status of completion of skill requirements in the classroom and on
the job. This matrix was the supervisors' tool for determining job assignments
for individuals', and foremen used it in job assignments to ensure that persons
were qualified. However, the inspectors learned that foremen were not always
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careful about making sure thatLjob assignments maximized on-the-job training
opportunities for unqualified personnel and that completed on-the-job training
was preperly recorded'to assure maintenance technicians were qualified in as
many skills as:possible, as quickly as possible.
Increased management attention
had shown improvement in this area.
Maintenance training needs were established in 1983 and had not been reviewed
or revised since that~ time. Training personnel agreed that additional training
needs had been identified and needed to be incorporated into the program. The
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inspectors found that approximately half of the maintenance foremen and
supervisors had received very little technical training,
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Discipline' supervisors indicated that the training department was generally
. responsive to training reeds. Maintenance craftsmen appeared well trained,
knowledgeable of the plant, and cognizant of safety hazards associated with the
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work site. However, supervisory training in administrative responsibilities
was not very effective and,-in some cases, hindered the maintenance process as
discussed in other sections of this report. This condition was exacerbeted in
the mechanical area,by the current shortage of staff (approximately 10 percent
,
under allowance) and the apparently high rate of turnover (approximately
10 percent per annum). The licensee should consider modifications in personnel
programs.that will increase technician retention and broaden the experience
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base.
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lThe inspectors 1found the licensee's perconnel control methods sufficient
- although future review by plant / corporate management was encouraged. The
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licensee had established and inplemented a drug screening program and has had
success in screening potential hirees. The training and qualification program
appeared adequate at the craft level but needed further attention by management
,
in the area of planners and system engineers. The plant staffing levels
$
appeared adequate to maintain the plant and keep work order levels and
backlog-to-workoff rates within acceptable ranges.
However, I&C planners were
understaffed and system engineers could t,e affected by projected terminations.
The inspectors were concerned about the financial health of the corporate
entity and resultant budgetary constraints affecting maintenance activities and
staffing.
Plc.nt performance indicators relative to plant expenditures showed
that the licensee expended large amounts of funds in preparation for and during
the second refueling outage.
In contrast, post-outage expenditures were
significantly.below projected norms. The inspectors informed the plant manager
that the future balance between funds, staffing, and enhancement programs
relative to maintaining a healthy and effective maintenance program will
require close and vigilant monitoring,
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EXIT IllTERVIEW
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The inspectors met with Mr. T. Plunkett and other members of the licensee's
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staff at the end of this inspection on October 6,1989. The inspectors-
sunearized the scope of the inspection and presented the inspection findings.
The licensee did not identify- as proprietary any of the materials provided to,
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or reviewed by, the inspectors during this inspection.
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0n October 17, 1989, Mr. J. Jaudon, Mr. J. Gagliardo, and Mr. J. Cummins held
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an exit interview with Mr. J. Deddens and other members of the licensee's staff
and discussed the scope and findings of the inspection.
Persons contacted by
the team and attendees at the exit meeting are identified in Attachment A.
The color-coded presentation tree (Attachment C) was used as a visual aid
during the exit meeting to depict the results of the inspection.
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ATTACHMENT A
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PERSONS CONTACTED
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The team also contacted'other members of the licensee's staff during the
inspection to discuss' identified issues ~.
Those persons with an asterisk preceding their name were in attendance at the
exit meeting held on October 17, 1989.
A
Licensee Personnel
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A. Abella, Field Engineer
R. Adamc, Issue Room Attendant
F. Allison, I&C Planner
J. Amburgey, Senior Nuclear Engineer
T. Anthony, Supervisor, Performance Program and Testing
R. Backen, Operations Quality Assurance
G. Baranek, Senior Planning and Scheduling Specialist
R. Barnes, Supervisor, Codes and Standards
W. Beck, Supervisor, Balance of Plant Design
M. Bissell, 18C Technician
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_B. Blose, Supervisor, Electrical Maintenance
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- J. Booker, Manager'- Oversight
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_M. Bourgeois, Issue Room Attendant
' W. .Bushall, Jr. , Nuclear Training Coordinator-- Maintenance
G. Bysfield, Supervisor, Control Systems
'G. Canfield, Measuring and Test Supervisor
- E._Cargill, Director, Radiological Programs
N. Carver, Director Employee Relations
D.,Chustz, Maintenance Support Supervisor
- J.; Cook, Lead Environmental Analyst
R. Cooke, I&C Technician
R. Coppo, NPRDS Data Section
- T. Crouse, Manager Quality Assurance
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L. Cununings, Senior Planning and Scheduling Specialist
K. Dawson, Field Engineer-
- J. Deddens, Senior Vice President.
- D. Derbonne, Assistant Plant Manager-Maintenance
- L.'Dietrich, Supervisor, Nuclear Licensing
P. Dinecola, I&C' Technician
C. Edwards, As Low As Reasonably Achievable Technician
M. Feltner, Engineer, Licensing
C. Foster, Tool Issue Foreman
'-
J. Fulkerton, I&C Technician
J. Galloway, I&C Technician
R. Gaylor, Co.mputer Systems - Field Engineering
E. Glass, I&C Supervisor (Acting)y Engineering
K. Giadrosich, Supervisor, Qualit
- P. Graten, Executive Assistant
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J. Hamilton, Director, Design Engineering
W. Hardy, Supervisor, Radiation Protection
R. Hebert, Supervisor Inventory Management
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- G. Henry, Director - Quality Operations
D. . Hill, System Engineer
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P.'Hughes Senior Licensing Engineering
J. JacA. Mechanical Maintenance Foreman
- D. J c yan, General Maintenance Supervisor
- L. Johnson, Site Representative.
A. Kugler, Supervisor, System Supervisor -
- G. Kime11, Director, Quality Services
'
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P. Lafort, Foreman, Radiation Protection
W. Leib, Mechanical Staff Assistant
- J. Levines, Director Field Engineering
D. Lorfino, Senior Licensing Engineer
R.-McCartney, Mechanical Maintenance Foreman
- D. Metcalf,-Quality Assurance Engineer
J. Morgan,-System Engineer
-
"J. Mullin,- Mechanical Maintenance Foreman
- V. Normand, Supervisor of Maintenance Services
G. Hunnery, IAC Technician
>
- W. Odell, Manager, Administration
F. Odom, Calibration Laboratory Supervisor
J. Oliver, Mechanical Maintenance Foreman
,
- T. Plunkett, Plant Manager
F. Prudhomme. I&C Foreman
'
R. Redmond, Quality Assurance Engineer
-
D. Reynolds, Administrative Support Supervisor
S. -Rima, Nuclear Training Representative
B.' Rogers, QC Inspector
A. Roshto, I&C Technician-
3
-
J.' Salmon, Systems Engineer
,
M. Sankovich, Manager, Engineering
- J. Schippert, Assistant Plant Manager -
-
J. Simpson,' Nuclear Maintenance Planning Supervisor
A. Smith, I&C Technician
,4
B. Smith, Senior._ Planning and Scheduling Specialist
'
A.-Soni,: Supervisor, Specifications and Qualifications
A. Speeg, I&C.; Staff Assistant-(Acting)
,
'G. Stout, I&C Technician
'T. Su, Field Engineer
,
- K. Suhre, Manager Pros Maintenance
,
L. Thompson, Senior Planning and Support Specialist
B; Trude11, Shift Supervisor
H. Uorthrop, Supervisor Warehouse Operations
-
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R. Yachon, Compliance Department
M. Vierra,'As-Low As Reasonably Achievable Technician
'
- C. Walker, Supervisor, Quality Control
C. ' Walling, Senior Mechanical Engineer
- R. West, Assistant Plant Manager, Technical Services
R. Whitley, Quality Control Inspector
F. Wilson, Senior Planning and Scheduling Specialist
D. Zemel, Mechanical Maintenance Supervisor
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NRC Personnel-
- G. L., Constable Chief, Reactor Projects Section C, Region IV
- J. E. Cumins, Reactor Inspector, Operational Programs Section, Region IV
- E. Ford, Senior Resident Inspector, Region IV-
. J. E., Gagliardo, Chief, Operational Programs Section, Region IV
'
- F. Hordon, Director, Project Directorate IV, Office of . Nuclear Reactor
Regulation, NRC Headquarters
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- J; P. Jaudon, Deputy Director, Division of Reactor Safety, Region IV
- W. B. Jones, Resident Inspector, Region IV
- W. Paulson, Office.of Nuclear Reactor Regulation, NRC Headquarters
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ACRONYMS :
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. automatic depressurization system
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JAEMt
acoustical emission monitor
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as low as reasonably achievable'
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- American Society of Mechanical Engineers
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, boiling-water reactor-
BWR; ,
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EPRI-
Electrical. Power Research Institute
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engineered safety feature:actuations
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.FCV
flow coolant valve
K
'GE
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general employee. training
- GL
generic letter
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.HP-
health physics
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.HPCS
high-pressure core spray-
N
hydraulic power unit
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sI&C'
instrument and control.
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'INPO
~ institute of nuclear power operation-
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'ISEG
Iindependent_safetyengineeringgroup
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' inservice test-
'LCO.
? limiting'conditionifor operation
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loop' calibration' report
LER
clicensee event. report
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S. LVDT -
linear variable differential transformer
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' linear velocity transmitter
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MEP:
maintenance. enhancement program
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< materials handling procedures
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' motor operated: valve
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~ measur;ing and test equipment
MTI
maintenance team inspection
- MW0,
maintenance work order-
MWOR..
maintenance work order request
-HPRDS-
nuclear plant reliability data systems
. OSHA
OccupationalfSafety:and Health Act
PH
preventive maintenance-
probabilistic' risk assessment
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PVLCS
.penetrat' ion valve leakage control system
QA:
quality assurance
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. quality control
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RBS-
' River Bend Station
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- RCA .
radiologically controlled area
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reactor core isolation cooling
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RHR-
RWP ,
. radiation work permit
SOER;
significant operating experience report
standby service water
SVV:
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temporary instruction
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updated safety analysis report
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