ML20006F540

Submits Addl Info Re Util Maint Program,Per NRC 900221 Telcon Request.Util Maint Program Includes Preventive, Predictive & Corrective Maint as Well as Implementation of Design Enhancements

ML20006F540
Person / Time
Site:	Seabrook
Issue date:	02/23/1990
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-90046, NUDOCS 9002280136
Download: ML20006F540 (13)

Text

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7' < *NeG Hampshire Ted C. F *,_ -E rr . . .

Senior Vice President and Chief Operating Officer -

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n 1-NYN-90046-February 23, 1990 United States Nuclear Regulatory Commission Washington, DC. 20555 Attentions. Document Control Desk ..

References:

(a) Facility Operating License No. NPF-67 Docket No. 50-443 (b) NHY Letter NYN-90021 dated January 25, 1990, " Request for >

Information", T. C. Feigenbaum to W. T. Russell (c) NHY Letter NYN-90032, dated February 6, 1990, " Request for Information" T.C. Feigenbaum to W. T. Russell (d). NHY Letter.NYN-90043, dated-February 21, 1990, "Seabrook -l Station Readiness". T. C. Feigenbaum to USNRC

Subject:

Request for'Information Gentlemen:

'In response to a request by members-of the NRC Staff during a

. telephone conversation on February 21,'1990, New Hampshire Yankee (NHY) is providing additional.information regarding our maintenance program.

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_ New Hampshire Yankee has completed all testing and preparatory activities required.for power ascension testing and subsequent plant L operations. The plant is ready to utilize a full power operating license.

The plant:is'currentlyiin MODE 3. Hot Standby, ready to enter MODE 2, Startup, and begin the power ascension test program upon issuance of a full-

-power operating. license.

The NHY-maintenance program includes preventive, predictive and corrective maintenance as well as the implementation of design enhancements.

Our goal;is to have 60% of our maintenance activities be preventive /

) predictive'with the remaining 40I corrective. The total maintenance program is defined and contro11ed'in accordance with a series of administrative programs and-implementing procedures. The maintenance program utilizes a computer based tracking system, a computerized scheduling program and a computerized technical specification surveillance tracking system.

9002260136 9002'3 2 )

PDR ADOCK 0500 3 g;

' New Hampshire Yankee Division of Public Service Company of New Hampshire \D\

P.O. Box 300 = Seabrook, NH 03874 + Telephone (603) 474 9521

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- United States Nuclear Regulatory Commission February 23,1990 Attention: Document Control Desk Page two As part of our maintenance program, we utilize a ' System Week" concept. Each week of the year is assigned'to one or more plant systems.

Within the System Week concept, any given system may be assigned multiple weeks of-the year. The System Week assignments are dependent upon the' size, ,

nature and importance of the system to safety and plant reliability. These System Week assignments allow the NHY Staff to focus on maintenance issues which may be unique to each system. This is particulary valuable in the implementation of our predictive and preventive maintenance programs. The System Week concept also allows the NHY Staff to properly preplan and i control the corrective maintenance activities associated with each system.

This concept also minimizes system down time due to maintenance activities.

Preventative maintenance activities are controlled by Repetitive Task Sheets (RTS). These documents ensure that preventative maintenance is planned in a consistent, controlled manner. We utilize a coordinated planning process to establish the workload for each System Week. This planning process ensures that the appropriate preventive and predictive maintenance is scheduled and performed. Mid-course corrections are provided through our daily " Plan-of-the-Day' (POD) meeting.

I The System Week concept does not schedule all maintenance activities.

. Corrective maintenance activities are controlled by the Work Request system.

Each Work Request is prioritized by the Operations Department when the Work Request is issued. The Operations Department prioritizes Work Requests by their potential impact on Plant Operations. This priority system ensures i

that maintenance on equipment required by the Technical Specifications, or

l. for concerns associated with equipment reliability or personnel safety.

l receives the appropriate attention. An explanation of each priority code is provided in Enclosure 1.

l New Hampshire Yankee has established the philosophy that all deviations from optimum plant conditions, however minor, will be identified and tracked in our maintenance program. It should be noted that for l

corrective maintenance we do not combine like components on a single Work Request. We have established a management goal of 750 open Work Requests.

This goal represents the number of open Work Requests expected to be in progress during normal, steady state plant operations. This goal is based upon our past experience, the size of the plant, and our philosophy of identifying each component deviation on a separate Work Request. Our experience indicates that during a routine week approximately 125 Work Requests are opened and closed. The process for a typical, medium or low

. - priority Work Request is as follows: We allocate one week to be used by the Technical Support Department to perform the research and engineering required to establish technical implementation requirements. The Planning and Scheduling Department is allocated three weeks to ensure parts

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l United States Nuclear Regulatory Commission February 23,1990 Attention: Document Control Desk Page three availability, assemble a coordinated work package, and schedule to an i

appropriate implementation window. Finally, the Maintenance and Operations p Departments are allocated two weeks to establish necessary system lineups:

personnel' equipment safety tagging requirements: implementation of the works retest after work completion and operability closeout. This process establishes the basis for the number of open Work Requests that we refer to L

as the "Vork Request Backlog'. A Work Request may be performed during the L plant. system's assigned preventative maintenance System Week, if the schedule for the System Week is appropriate for the priority of the Work-L Request. For High Priority, E and Priority 1. Work Requests, the process described above is initiated immediately and worked continuously until completion. Priority 2 Work Requests are expedited as appropriate.

The NHY Work Request backlog history is provided in Enclosure.2. You l

will note that as of February 19, 1990, we had a backlog of 751 Work l' Requests, one over our steady state operating goal. On February 12, 1990, the backlog was 713 Work Requests, 37 under our steady state operating goal.

This fluctuation from week to week is expected. The number of open Work Requests will fluctuate around the 750 value during normal plant operation.

Of the 751 Work Requests open on February 19th, 97 were associated with safety-related systems. None of these Work Requests are required to be completed to satisfy Technical Specification requirements or to commence power ascension testing and subsequent operation of the plant. Of the 97 open Work Requests associated with safety-related components or systems, please note the following:

l - NHY presently has no Priority E open Work Requests.

- NEY presently has two Priority 1 open Work Requests. One additional Priority 1 Work Request has been closed since February 19, 1990.

On February 17, 1990, a Work Request was initiated to address a low nitrogen gas pressure alarm on a feedwater isolation valve actuator. The actuator was recharged immediately. The Work Request is in the documentation sign off process.

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On February 21, 1990, a Work Request was initiated to address a containment radiation monitor intermittent spiking problem.

Corrective maintenance has been completed and the Work Request is in the documentation signoff process.

- As of February 19, 1990, 9 of NHY's 91 Priority 2 open Work Requests were associated with safety-related components or systems. Of these, only two are greater than two months old, both generated in October, 1989. One of these Work Requests involves a

y United States Nuclear Regulatory Commission February 23,1990 Attention: Document Control' Desk Page four cracked auxiliary contact in a switchgear disconnect assembly which is presently awaiting spare part delivery. The second Work Request involves a minor body to bonnet flange leak (a drip) in our Containment Building Spray System. This Work Request is awaiting proper system conditions. l

- As of February 19, 1990, 70 of NHY's 542 Priority 5 open Work d Requests were associated with safety-related components or systems. These items will be addressed per our normal system week process.

- As of February 19, 1990, 15 of NHY's 115 Priority 4.open Work Requests were associated with safety-related components or j systems. These items will be addressed per our normal .i maintenance programs.

Priority 3 and 4 Work Requests encompass a wide range of different equipment issues, which may include packing adjustments, equipment labeling

'improvements, minor equipment vibrations, etc. All of the above Work ,

Requests are processed through our normal maintenance program.

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I The NHY Maintenance Group is composed of the Instrumentation and Control Department, the Radwaste/ Utilities Department, and the Maintenance Department, which includes the mechanical and electrical disciplines. The' Maintenance Group has an authorized staff of 205 personnel with approximately 1,580 man years of nuclear power plant experience, including -:

approximately 950 man years at Seabrook Station. We have compared our maintenance staffing with the industry and based upon our reviews and i experience,'we believe that the current staffing levels are appropriate.

Additionally, we_do have the ability to supplement our maintenance organization with craft personnel and New England Power Service Company personnel for the completion of outage work. Typically, we have used craft labor to assist us'in the installation of system additions and enhancements  ;

'(backfits). In this way the Maintenance Group resources are not adversely i detracted from their_ primary mission.

i We have established management' goals to maintain the nornal level of maintenance overtime less than the equivalent of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per man per week during normal plant operation. We believe that this is an appropriate level j that will support variations in the workload and allow us to effectively L accommodate vacations, sickness, and other work force fluctuations. The NHY l Maintenance Group overtime history'is provided in Enclosure 3.

l The period of time covered in Enclosure 3 essentially corresponds to the duration of our recent maintenance outage. Overtime was utilized based

.upon the requirements of the outage work scope. Due to the length of time between initial fuel load, receipt of the 5% license, and our need to L maintain plant readiness for full power operations, the majority of our 18 l

month surveillances were reperformed. In addition, although the plant had ,

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United States Nuclear Regulatory Commission February 23,1990 Attention: Document Control Desk Page five not been operated for any appreciable length of time, many of our major equipment overhauls, such as our Emergency Diesel Generators, which are coordinated by Repetitive Task Sheets, also were performed. Thus, this outage was comparable in scope to a major refueling outage. The work

-activities performed by the Maintenance Group included the completion of numerous Technical Specification surveillances, preventive maintenance

'Repetitivo Tash Sheets, major equipment preventive maintenance overhauls, as well as Work Request completion activities. Due to the nature of the  ;

Maintenance Group's scope of work there is no direct comparison between l Enclosure 2 "Seabrook Station Work Request Backlog', and Enclosure 3

'Seabrook Station Maintenance Group Overtime". The overtime hours include all of the overtime associated with the aforementioned activities, and not just the overtime associated with Work Request activities. In addition, the  ;

scope of_one Work Request, by its nature, may have more manpower requirements than many other Work Requests combined. For example, the reeleeving of one of the primary component cooling water heat exchangers required an extensive allocation of manpower, but was controlled by only one Work Request. The overtime levels have trended down to where for the week of February 24, 1990, we project that the overtime level will approach our steady state goal. We believe that our process for controlling overtime is effective.

We believe that we have a well coordinated maintenance program that {

is effectively implemented by an experienced, dedicated maintenance group.

Our maintenance training programs will receive INPO accreditation review in April of this year. We expect that our maintenance training programs will receive accreditation later this year. We will continually monitor our performance in the maintenance area and will make any improvements as necessary.

h In summary, the testing and preparatory activities required to begin i power ascension testing and subsequent full power operation have been l

completed. . Additionally, there are no outstanding maintenance activities

! that would preclude NHY from utilizing a full power operating license. The NHY maintenance program is in place and is effectively controlling the planning, scheduling and performance of maintenance activities.

Should you require additional information regarding this matter, please contact Mr. Terry L. Harpster, Director of Licensing Services, at (603) 474-9521, extension 2675. y'

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Verygulyyours,

'jg/ / qfiv k ~

V Ted . FeigenbA4 9

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United States Nuclear Regulatory Connission February 23,1990

. Attentions- Document Control Desk' Page six cci -Mr. William T. Russell-Regional Administrator United States Nuclear Regulatory Connission Region I g 475 Allendale Road i

King of Prussia, PA 19406 i; Mr. Victor.Nerses, Project Manager' Project Directorate I-3 United States Nuclear Regulatory Commission Division of Reactor Projects Washington, DC- 20555, Mr. Noel Dudley.

NRC Senior Resident Inspector P.O.. Box 1149 Seabrook, NH 03874 i

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- New' Hampshire Yankee February 23.1990 m

4 44 i Enclosure 1 to NYN-90044 Seabrook Station Work Request Priority System O.

WORK REQUEST PRIORITY DEFINITION PRIORITY E i

Emergency maintenance action is taken to prevent or mitigate the consequences of an accident, prevent the release of radioactive material to the environment._to protect human life and/or property, or restore the ability of'the' operator to obtain information from the plant computer. Emergency maintenance is performed at the discretion of_the Shift Superintendent and may start without an approved Work Request. Priority E Work Requests are not downgraded once work has started.

NO WORK REQUESTS PRESENTLY OPEN PRIORITY _1 Priority 1 applies to repairs, replacements, or modifications' required to restore a system or function to operable status tot

a. Decrease the risk of radiation exposure to the public, b, eliminate a personnel safety hazard, c.- return the plant to full power operation,

d. satisfy a Technical Specification limiting condition for operation,

e. return the backup plant computer to operation, or

f. return accident monitoring instrumentation (AMI) or back-up AMI devices to operation.

Priority 1 Work Requests are also utilized to address non-reactor plant items which require immediate attention. These Work Requests are worked continuously from the time they are initiated until the work is

. complete.

2 WORK REQUESTS PRESENTLY OPEN AGE: LESS THAN ONE WEEK PRIORITY 2 Priority 2 applies to repairs, replacements, or modifications required based on an existing condition which, if allowed to persist, has high probability of impacting the plant's ability to maintain a system or function in operable status. Priority 2 also applies any personal h protection and/or safety concerns not covered by Priority 1.

AS OF 2/19/90, 91 OPEN REQUESTS OF WHICH 9 ARE ASSOCIATED WITH SAFETY-RELATED COMPONENTS / SYSTEMS

F -e WORK REQUEST PRIORITY DEFINITION (Continued) ,

PRIORITY 3 t

Priority 3 applies-to those work items which are considered to be of medium priority. The assignment of a Priority 3 applies to those repairs, replacements, or modifications which may be performed as manpower or other scheduled activities allowed (i.e., System Week) i e

AS OF 2/19/90, 542 OPEN WORK REQUESTS 0F WHICH 70 ARE ASSOCIATED WITH SAFETY-RELATED COMPONENTS / SYSTEMS ,

e PRIORITY 4 Priority 4 applies to those work items which are considered to be low priority. The assignment of a Priority 4 applies-to those repairs, replacements, or modifications which may be performed as fill-in work.

i AS OF 12/19/90, 115 OPEN WORK REQUESTS OF WHICH 15 ARE ASSOCIATED WITH SAFETY-RELATED 00MPONENTS/ SYSTEMS 9

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S Enclosure 2 to NYN-90044 ,

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r Seabrook Station Work Request Backlog .

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.Seabrook Station WORK REQUEST BACKLOG 2,000 1,750

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Enclosure 3 to NYN-90044 -.

Seabrook Station Maintenance Group Overtime l

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