ML20034A289

Maint Team Insp Rept 50-289/89-82 on 891204-15 & 900122-25. Violations Noted.Major Areas Inspected:Maint Program & Implementation

ML20034A289
Person / Time
Site:	Crane
Issue date:	04/10/1990
From:	Baunack W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20034A282	List: ML20034A281 ML20034A284 ML20034A289
References
50-289-89-82, NUDOCS 9004200736
Download: ML20034A289 (55)

See also: IR 05000289/1989082

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.:

50-289/89-82

Docket No.:

50-289

License No.:

DPR-50

Licensee:

GPU Nuclear Corporation

P.O. Box 480'

Middletown. PA 17057

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Facility Name: Three Mile' Island Nuclear Station.. Unit 1 -

Inspection Conducted:

' December 4 - 15, 1989 and January 22 - 25, 1990

Team Members:

R. Hernan, licensing Project Manager, NRR

D. Johnson,. Resident Inspector, TMI-1

T. Rebelowski, Senior Reactor Engineer, Region I

S Sherb1ni, Senior Radiation Specialist, DRSS, Region I

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Team Leader:

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..Baunack, Senior Reactor Engineer

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Division of Reactor Safety-

Inspection-Summary:

A special announced maintenance team inspection of the'Three Mile Island, Unit

1 Maintenance Program and its implementation was performed.

The inspectors

used the NRC maintenance inspection guidance in Temporary Instruction 2515/97.

Results:

Overall, the maintenance program and its implementation were found to'be

adequate. Areas of strengths and weaknesses are:1dentified-in the executive

summary and discussed in the report. One' violation was identified with three

examples of failure to follow procedures.

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TABLE OF CONTENTS

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EXECUTIVE SUMMARY

INTRODUCTION

1.0 Overall Plant Performance Related to Maintenance

2.0 Management Support of Maintenance

2.1 Management Commitment and Involvement

2.2 Management Organization and Administration

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2.3 Technical Support

2.3.1

Internal Corporate Communications Channels

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2.3.2 Engineering Support

2.3.3

Licensee Acknowledgement of Risk Significance in the

Maintenance Process

2.3.4 Quality Control in the Maintenance Process

2.3.5 Integration of Radiological Controls'in Maintenance

ActiviLies

2.3.6 Safety Review of Maintenance Activities

2.3.7

Integration of Regulatory Documents into the

Maintenance Process

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3.0 Maintenance Implementation

3.1 Work Control

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3.1.1

Review of Maintenance in Progress

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3.1.2 Work Order Control

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3.1.3 Equipment Records and History

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3.1,4 Job planning

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3.1.5 Work Prioritization

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3.1.6 Maintenance Work Scheduling

3.1.7 Backlog Controls

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3.1.8 Maintenance Procedures

3.1.9 Post Maintenance Testing

3.1.10 Review of Completed Work Documents

4.0 Plant Maintenance Organization

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4.1 Control of Plant Maintenance Activities

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4.2 Control of Contracted Maintenance

4.3 Deficiency Identification and Control

4.4 Performance of. Maintenance Trending

4.5 Establish Support Interfaces

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5.0' Maintenance Facilities, Equipment and Materials Control .

5.1 Maintenance Facilities and Equipment

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5.2 Material Controls

5.3 Establishment of Maintenance Tool and Equipment Control

5.4 -Control and Calibration of Metering and Test Equipment

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6.0 Personnel Control'

Attachment 1

Pre-Inspection Requested Information

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' Attachment 2

Persons Attending. Exit Meetings

Attachment 3

.$ummary of Weaknesses

Figure =

1~ '. Maintenance Inspection' Tree-

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EXECUTIVE SUMMARY

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An in depth team inspection of the Three Mile Island Unit 1 maintenance program

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and its implementation was performed December 4-15, 1989 and January 22-25,

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1990. The inspection included a review of maintenance documentation,

observations of maintenance work in progress, and discussions with personnel,

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The inspection team evaluated three major areas: (1) overall plant performance

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related to maintenance; (2) management support of maintenance; and (3)

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management implementation. ' Under each of these areas, elements considered

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important for proper function of the area were inspected.

For each element,

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the inspectors evaluated both the program and how effectively the program is

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implemented. The inspection results are summarized in the following

paragraphs, and are discussed in detail in the body of the report.

Several

weaknesses were identified.

These are listed in Attachment 3.

In addition,

one violation, with three examples of failure to follow procedures was noted.

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Overall plant Performance Related To Maintenance

Since-plant restart following the long outage resulting from the TMI-2 accident

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the plant performance has been very good characterized by long periods of-

continuous operation and outages completed within the time scheduled. The last

operating cycle included a 335 day continuous run.

Observations of work in

progress indicated that maintenance is being performed by skillful, knowledgeable,

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and competent personnel.

Maintenance work is well supervised and overview of

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the work and associated documentation by management personnel is consistent and

of high quality. The one violation identified in this area.is not considered

to be indicative of.a breakdown in work control. ' Appropriate licensee supervision

over work performed by contractors was also evident.

The general status of housekeeping was very good. Although certain areas were-

observed where improvement was indicated. Management performs routine housekeeping

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inspections.

These inspections vary from superficial to very detailed.

In

general, most personnel were conscious of the need to practice well-disciplined

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work habits, good housekeeping, and the need for adherence to' administrative

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controls.

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Management Support of Maintenance

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The overall management support of maintenance at both the site and corporate

level is strong and effective. Significant resources have been allocated,

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especially to the staffing of the material assessment group. Major

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initiatives have been taken to establish and maintain an effective maintenance

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program. An adequately documented maintenance plan has been implemented at

the site, although no comprehensive planning document exists'to control long

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terai activities.

Overall, adequate engineering support has been provided to the maintenance

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organization. Good communication exists between maintenance and other

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site / corporate entities.

Engineering support for plant maintenance activities

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is obtained through the implementation of engineering evaluation requests

(EER). A weakness in the administrative processing of EERs was identified.

Better control has been established through recent changes to the procedure

which governs the use of EERs.

Currently, a large eacklog of open EER$ exists.

Corporate policies are delineated in procedures, in addition a significant

effort is underway to upgrade maintenance procedures. The licensee has

initiated an aggressive program to improve preventive maintenance, as well as -

other aspects of maintenance, on the basis of risk assessment information.

Quality control involvement in maintenance activities is well documented and

adequately implemented.

Effective procedures have been established and

deficiency trending is performed.

Radiation exposure reduction efforts have been effectively incorporated into

maintenarce activities.

Site exposure totals are toward the lower end of

collective exposures observed in the nuclear industry for reactors of similar

size and design. Adequate safety measures have been integrated into the

maintenance process. A process for the review of regulatory and other documents

has been established and appropriate changes to equipment and procedures have

resulted from the review of these documents.

Maintenance Implementation

The team concluded that work is generally performed in a controlled manner, in

accordance with procedures and is adequately supervised. A new computerized

system for the generation of work documents as well as recording maintenance

history has been implemented.

Controls have been established to ensure

maintenance tasks are appropriately planned, prioritized, and scheduled.

Realistic

maintenance backlog goals have been established and the backlog is maintained

below these goals. The ratio of corrective to proventive maintenance indicates

an effective preventive maintenance program. The team concluded that adequate

control and excellent supervision was provided for the performance of

maintenance work.

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Procedures are extensively used-in the performance of maintenance and a

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program has been initiated to further improve maintenance procedures.

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However, problems which are summarized below were noted in.the documentation

of various maintenance activities that included deficient or not' issued

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procedures; the failure to document activities as required by procedures; and

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the failure to properly implement a document control system.

Some of these

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documentation problems were incorporated in a notice of violation associated

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with this report and other were considered weaknesses.

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Additional work was to be performed on the diesel generators which were.

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already tagged out. Although verbal permission was obtained to do the

work, clearance was not documented on the clearance control document.

This was identified as violation.

In addition, numerous minor errors were

noted in the documentation of other tagouts.

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There was extensive use of generic procedures in corrective maintenance

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activities. Technicians performing the work had latitude without further

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pre-review to determine which procedural steps were applicable. This was

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considered a wet.kness.

Documentation associated with post maintenance testing (PMT) was deficient

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in that the PMT which was to be performed was net always clearly specified.

Likewise the PMT which was performed was r.0t always clearly documented.

This has been recognized by the licensee and procedures are being prepared

to correct this deficiercy.

A weakness was identified in the control of vendor. manuals.

Some manuals

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had been lost or misplaced and the number of vendor manuals were not entered

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into the system.

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The control of contractors was adequate although no formal program existed

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describing the controls. The licensee indicated that a comprehensive

procedure will be developed to formalize contractor control.

Although an effective and improving predictive maintenance program is in

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place, some effort is still needed to formalize in procedures the

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implementation of certain programs.

Procedures which govern the use of wire rope, synthetic slings, and hand

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operated hoisting equipment were deficient in the areas of control and

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testing. These deficiencies were not identified during licensee biennial

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reviews of the procedures.

A violation was identified in that measuring and test equipment usage

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cards were not being filled out as required by procedure.

In addition to

the violation, the team was concerned that a similar problem had been

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identified by QA and adequate corrective action apparently was not taken.

Systems have been implemented for.the identification of deficiencies. QA has

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also been requested by maintenance to assist in the identification of deficiencies

in maintenance activities. An adequately documented and implemented trending-

program which includes root cause analysis has been implemented. Also, good

interfacing between maintenance and other site organizations was noted.

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team observed that QA had also identified deficiencies in documentation of work

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activities.

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Improvement in the storage of some material in the warehouse is warranted.

Likewise, the in plant storage of equipment in the shop areas was not

conducted in accordance with procedural requirements.

Improvement is needed

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in the . implementation of corrective actions taken in response to similar

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deficiencies identified by QA.

The licensee has taken steps to improve physical maintenance facilities. A

number of improvements are currently under construction. Good use is'made of

diagnostic equipment, and additional equipment is being evaluated to assist in

the improvement of the preventive maintenance program.

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. The licensee has a stable, experienced work force. A six shift maintenance work

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rotation schedule has been-established which provides maintenance personnel on

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site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, This rotation schedule.also provides adequate time for

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training. A dedicated maintenance training group has been established to provide -

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the training for maintenance personnel which is determined to be necessary.

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training program for management. and supervisors ~ is being formalized.

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INTRODUCTION

Background

The Nuclear Regulatory Commission considers the effective maintenance of

equipment and components'a major aspect of ensuring safe nuclear plant operations

and has made this objective one of the NRC's highest priorities.

To this end,

the Commission issued a revised Policy Statement dated December 8, 1989, that

states the commission desires to have in place an industry wide program that

will ensure effective maintenance is achieved and maintained over the life of

each plant.

To ensure effective implementation of the Commission's maintenance policy, the

NRC staff will continue to inspect and evaluate the effectiveness of licensee

maintenance activities. This inspection was one of a series being performed by

the NRC to evaluate the effectiveness of maintenance activities at-licensed

power reactors.

The inspection was conducted in accordance with.the guidance

provided in NRC Temporary Instruction 2515/97 and the-NRC Maintenance Inspection.

Guidance. The temporary instruction includes a " Maintenance Inspection Tree"

that identifies for inspection the major elements associated with effective

plant maintenance.

Scope of Inspection

The maintenance inspection at the Three Mile Island, Unit 1 Nuclear Station

(TMI-1) was initiated through a meeting between the team leader and a member

of the lic.ensing group on November 16, 1989 where the scope of the inspection,

including the function of the maintenance inspection tree was discussed.

~ packages of site-specific inforniation were provided by the licensee in response

to a letter from the NRC-requesting certain information dated October 2, 1989.

A copy of-the attachment to the October 2, 1989 letter is included in this

report as Attachment 1.

TMI-1 was operating during the first phase of this

inspection. The plant was shutdown for refueling on January 5, 1990 and remained

shutdown during the second phase of the inspection.

From November 20, 1989 to December 1, 1989, the team revlewed the information

provided by the licensee in preparation for the onsite inspection. 'The team

conducted onsite inspections from December 4-15, 1989 and January.22-25,

1990. Maintenance at the facility is performed by the Plant Material

Department.

Consequently, maintenance group and plant material are used

interchangeably in the report.

The-onsite inspection focused on the observation of maintenance work in

progress at the site and on licensee activities supporting this work,

including support provided by the engineering, training, and management

organizations.

Maintenance activities selected for detailed review included

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equipment identified in the probabilistic risk assessment as having the potential

for contributing significantly to core damage accident sequences or to the

reduction of the risk associated with plant operations. Other maintenance

activities were selected for inspection based on the scope of work in progress

during the inspection, recent failures of safety-related equipment, special

interest items, and NRC inspection experience.

Daily meetings were held by'the NRC team leader with plant management and

maintenance supervision to summarize the inspection team findings and identify

areas where additional information was required.

On December 14, 1989 a special

meeting was held to discuss the team's preliminary findings with the licensee's

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management. A summary of the inspection team's findings, including a presenta-

tion of an evaluated maintenance inspection tree, was d 3 cussed with licensee

representatives at exit meetings on December 15, 1989 and January 25, 1990.

Persons attending exit meetings are identified in Attachment 2.

The Maintenance Inspection Tree

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The inspection team's conclusions about the status of the plant's mainte' nance

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prograni are indicated by colors (green, yellow, red or blue) on the Maintenance

Inspection Tree (Figure 1).

For parts II and III of the tree, the upper left

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portion of each block indicates how well the topic of the block is described

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and documented in the plant maintenance program, includin

The lower right portion of each block indicater the team'g adequacy of procedures.

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effectiveness of implementation of the topic covered by that block. . Green

indicates that the program is well documented or that the program implementation

is effective. However, even for blocks shaded green, some areas for improvement

may be indicated in the report.

Yellow indicates an acceptable condition which

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could be strengthened and red indicates the topic is missing or the intent of

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that portion of the tree is not being met by maintenance activities.

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indicates the item was not evaluated or could not be properly evaluated due to

recent changes.

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Inspection Findings

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The inspection team's findings and conclusions regarding TMI-l's site

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maintenance program and its implementation are documented in Sections 1.0

through 6.0 of this report. Weaknesses which were identified are listed in

Attachment 3.

One violation with 3 examples for failure to follow procedures

was identified and is discussed in Paragraphs 3.1.1 (b), 5.2, and 5.4 of this

report.

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1.0 Overall Plant Performance Related to Maintenance (Direct Measures)

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Scope

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The~ objective of the inspection in this area was to assess overall plant

performance as related to maintenance by conducting plant system walkdowns,

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reviews of procedures intended to initiate and control plant maintenance

activities and by direct inspections of in progress and completed maintenance

activities. The material condition of the plant,~ including housekeeping and

general upkeep, and the overall level of personnel knowledge and management

involvement in the final work product were also assessed by these direct

measures.

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Findings

During the three operating cycles since plant restart in October 1985, TMI-1

has achieved an excellent operating history. This history has been documented

in NRC annual SALP reports and published performance indicator documents. The-

reactor trip rate, Engineering Safeguards Features (ESF) actuation rate,

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occupational radiation exposures and forced outage rates during this period

have been below the national average. The plant operated from October 1988 to

November 1989 at power without a reactor trip. This excellent operating

record is attributed by the team to be indicative of the implementation of

both a good preventive maintenance program and the effective performance of

corrective maintenance.

The team conducted walkdown inspections of plant systems and maintenance in

progress to assess the extent to which safe and effective' work practices were

utilized by plant personnel.

The team also observed housekeeping and the

arrangement and use of tools, equf pment, scaffolding, temporary support struc-

tures, system tagouts, identification of deficient conditions, compliance with

- administrative and maintenance procedures, operations / maintenance department

interface and control of electrical fuses.

The team observed maintenance work.

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and electrical modifications on the "A" emergency: diesel generator, the maio

steam system safety relief valves, relay calibration, weld repair of a piping

system and replacement of a valve diaphragm.

Major work'that was in progres$

afforded the inspectors an opportunity to observe typical performance of licensee

- maintenance activities during both operating and shutdown periods. The inspectors

observed that most personnel were conscious of the need to practice well-disci-

plined work habits, to maintain good housekeeping during the work and to ensure

that tools, equipment, temporary structures /encinsures and administrative

controls are used in a safe and efficient manner.

The work area was maintained

in an orderly manner during the work and was promptly cleaned up upon comple-

tion of the work in all cases observed.

Periodic overview by quality control

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and engineering personnel during the course of the work was evident.

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The team identified a noncompliance with plant administrative procedures for

switching and tagging of systems. Administrative procedure number Ap-1002,

Rules for the Protection of Employees Working on Electrical and Mechanical

Apparatus, states that more than one party may perform work under the same red

tag series provided that each party obtains release to work on the clearance

control document.

Electrical modifications were performed under work control

number CW-422 on December 4 - 5, 1989, on the "A" Emergerty Diesel Generator

(EG-Y-1A) by the plant maintenance electrical department.

Howwer. release of

this work was not documented on either day on the clearance control document

for work on this component under tagout control No. 89-1331.

This work was

unrelated to any work listed on the application forms processed for tagout of

the diesel generator to isolate the component for annual inspection and test /

repair / reset of various relief valves on the unit.

Although adequate tagout

protection was, in fact, provided to the electricians performing modifications

to the "A" emergency diesel generator controls at the time the work was in

progress, adequate awareness via the clearance control document required by

AP-1002 did not exist to protect the electricians had the diesel annual maintenance

been completed before the modification work.

Other unrelated electrical work

relying upon this tagout (e.g. calibration of protective relays by the Lebanon

Relay Division) was covered in accordance with AP-1002 by both a tagging appli-

cation and daily entries on the clearance control document.

Explicit compliance

with the procedure would have provided positive control of clearance of the

tagout and protection for the workers.

The team, based upon system / area walkdowns, judged the general status of

housekeeping practices to be very good. Although the overall material condition

of the plant has supported continuous operation in excess of 335 days during

the current operation cycle, there were a few observations that indicate that

the concept of " pride of ownership" can be improved in certain plant areas.

Certain areas such as the 333 foot elevation of the auxiliary building in the

area of the boric acid mix tank show neglect of good housekeeping practices.

Although this area is included in monthly management tours, review of the

management inspection reports indicates that these tours are superficial in

some cases. On the other hand, many of the monthly tour reports reviewed were

very detailed. Overall, housekeeping in most_ plant areas is very good.

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Observation of work in progress and review of completed work documents indicated

that maintenance is being conducted by. skilled, competent and knowledgeable

personnel. Maintenance work is well supervised and overview of maintenance

work and associated documentation by management personnel is consistent and of

high quality. As indicated in following sections _ of this report, the licensee

has developed a fairly sophisticated and reliable system of generating maintenance

documents and maintenance personnel are well trained and confident in the system's

capabilities. The low rework rate is indicative of the overall success of

craftsman competence and administrative controls.

Craftsman training and

knowledge of equipment are strengths in the licensee's maintenance program.

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Conclusion

General control of maintenance work and housekeeping were judged to be adequate

with. improvements deemed warranted in housekeeping of the Auxiliary Building.

A competent well supervised and well man 6ged maintenance organization has been

established. A very successful current operating cycle confirms the success of

measures taken to improve the quality of maintenance over the past several

years.

2.0 Management Support of Maintenance

Scope

This portion of the inspection was conducted to assess plant and corporate

management's support of maintenance activities with respect to the establish-

ment, implementation, and control of an effective maintenance program. The

major areas evaluated were management's connitment to' and involvement in the

organization and administration, resource' allocation, and technical support

provided to the maintenance organization. Discrete elements within these

areas, such as a documented maintenance plan, self-assessment measures,

resource allocation, definition of maintenance requirements, and accountabi-

lity, were evaluated to provide a basis for the team's overall assessment.

2.1 Management Commitment and Involvement

Scope

The objective of this inspection area was to evaluate corporate-level and plant

management's commitment to and involvement in assuring the adequacy of plant

maintenance as indicated by corporate level interest and participation in the

continuing assessment and improvement'of the maintenance program and its

support for industry initiatives and plant management's awareness of the status

of the maintenance program and the implementation of maintenance activities.

Findings

The team evaluated these elements through informal discussions and formal

interviews with the plant staff and reviewed the licensee planned, in progress,

or completed activities with respect to industry initiatives, industry event

communications, and the licensee's experience and data analysis of plant

performance.

The plant management representatives interviewed indicated strong support and

interest in the proper performance of plant maintenance. Their commitment and

support for improved maintenance was evident by the initiatives implemented.

lThe plant material assessment group was particularly effective in this respect.

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Major initiatives included participation in several industry programs. Three

management / staff personnel have participated in the INPO " Peer Evaluation

Program" and corporate wide goals support this program. A maintenance self-

assessment has been completed and corrective actions implemented from the

self-assessment findings. The licensee participates in the Babenck and Wilcox

(B&W) owners group and had completed several system upgrades, that were

recommended by the owners group Safety Performance Improvement Program (SPIP).

Other SPIP generated items are planned to be completed during the current

outage.

The licensee has a fully accredited training program and also participates in

the Nuclear Plant Reliability Data System (NPRDS).

The system is routinely

used to enter and retrieve equipment failure data.

The licensee has incorporated

the Human Neformance Evaluation System (HPES) into maintenance activities.

The HPES process has been used on several occasions to establish the root cause

of maintenance personnel performance problems.

A corporate level plan was issued which documented management responsibilities

and goals for the Plant Materiel Department. .This plan was translated to

another comprehensive site administrative procedure for the conduct of maintenance.

Both procedures were viewed as an overall strength of the licensee management

support of the maintenance program. Additionally formal procedures for root

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cause analysis of maintenance problems and also for trending maintenance history

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for individual components were available. . Data generated by use of these

procedures was factored into the basic maintenance program. Additional efforts

to reevaluate for possible improvement the preventive maintenance program in

several specific areas was noteworthy.

Conclusions

Overall management support at the plant and corporate level appeared strong and

effective.

Significant resources had been allocated, especially to staffing

the material assessment group.

Major initiatives have been taken to establish

and maintain an effective maintenance program.

2.2 Management Organization and Administration (Corporate and Plant)

Scope

The objective of the inspection in this area was to assess the effectiveness of

the organization and administration of the Plant Materiel Department and the

maintenance program, respectively.

The specific areas inspected to provide a

broader perspective of maintenance activities included:

the existence,

availability, and scope of a formal maintenance program, maintenance policy

goals and objectives, allocation of resources, and identification and definition

of maintenance requirements.

The team evaluated these areas to provide a basis

for the overall-assessment and conclusion,

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The team determined that TMI has a formalized set of documents at both the

corporate and site level which clearly spell out policies, objectives, and

responsibilities for conduct of maintenance.

Provisions have been established

for reviewing these documents on a biennial basis.

The licensee has established Plant Materiel Department goals based on these

procedures and the progress made in achieving these goals is reported to

management on a quarterly basis. Good progress was being made on the 1989

goals as noted in the quarterly reports issued to date, which were reviewed by

the team.

Plant management has demonstrated a generally high interest in improving

maintenance activities as evidenced by consistent attendance at the daily

planning meeting and by conducting regularly scheduled plant walkdown tours.

A review of current maintenance activities conducted during the present

operating cycle (sixteen months of operation) indicated that the licensee has-

allocated sufficient resources in manpower and material to allow efficient

performance. A formally documented procedure controls the use of overtime and

management involvement in controlling both plant and contractor personnel work

hours was evident.

The reorganization of the Plant Maintenance Department during the past year

into the Plant Materiel Department resulted in significant changes and staffing

increases. The Plant Materiel Department now has three separate _ functions:

performance of maintenance, completed work assessment and job planning. The

planning department is staffed by experienced personnel who are knowledgeable

of overall plant operation. The engineer / analyst positions in the materiel

assessment section have been utilized effectively in activities such as

reliability-centered maintenance reviews, root cause analysis, and maintenance

trending. Additionally, these personnel have conducted and are continuing to

conduct reviews of such items as preventive maintenance schedules, and component

failures. These activities have resulted in significant improvements in the

motor / pump lube oil program.

Improvements'in diaphragm valve maintenance and

electrolytic capacitor replacement schedules are being planned.

Trending of maintenance problems has been accomplished on a formal basis since

1981. Maintenance Trend Action Notices (MTAN) are transmitted to various levels.

of site management on a quarterly basis. These notices require action of various

site organizations (engineering, QA, operations) to resolve the problems and

take corrective action. _Recent repairs to RM-A-2 (reactor building atmospheric

radiation monitor) and other similar monitors was completed based on action

from these trending reports. Root cause analysis has been formally implemented

via a procedure which uses the Kepner-Tregoe method. These analyses have resulted

in successful repairs to various components as evidenced by few repeated similar

failures. Maintenance program QA audits have been completed on a biennial basis

and corrective actions requested of the material department have been adequately

tracked to completion for audits reviewed by the team.

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The maintenance decision process for the short term is based on active partici-

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pation in daily. meetings which are driven by a comprehensive weekly schedule.

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maintained by the material planning group.

Long range planning is made on an

as needed basis. Several long range initiatives have been or are being

-

implemented. The initiatives appear to be the. result of individual effort

based on reaction.to equipment failures,1 cost analysis or personnel feedback,

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No documented plan for scheduling long term maintenance has been established.

The life of system maintenance plan specified in the corporate administrative

i

procedure does not have an implementing procedure but rather is a concept based

i

on the total information contained in Generation Maintenance System II (GMS-II).

Conclusions

Based on the above findings,.the team concluded that the licensee maintains an

1

adequately documented maintenance plan that it implemented at various levels of

F

the site organizations. Although upgrades a.nd adjustments.have been made to

the program on an as-needed basis, no comreehensive planning document exists to

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control long term activities.

'

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2.3 Technical Support

Scope

The team evaluated the technical support that the maintenance organization

receives from other parts of the organization, such as Engineering, Health

,

Physics, Quality Assurance, Quality Control and Operations. The evaluation

consisted of a review of the licensee's established policy, goals, and objectives

and an assessment of their effectiveness.

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2.3.1 Internal Corporate Communication Channels

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Scope

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The intent of this part of the inspection was to evaluate the licensee

,

communication systems to assure that' corporate policies for the maintenance

organization are incorporated into. plant procedures and that a feedback system

has been established to identify maintenance concerns to management for

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information and action as required.

.

Findings

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The team found that communication of maintenance concerns to other parts of the

[

"

organization is accomplished via several mechanisms.

Daily meetings, e.gc Plan

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of the Day (POD) and morning operations / maintenance interface meetings are

!

conducted to identify maintenance concerns to other organizations.

,

Input from the afternoon POD session is factored into the next 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> schedule

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for conduct of maintenance activities.

These meutings were effective in

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establishing priorities and reviewing inter-related concerns that could affect

the. work in progress.

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In order to insure corporate policies are uniformly applied, the maintenance

organization has recently developed a writer's guide for all maintenance pro-

cedures. This guide was reviewed by the team and was considered to be an

effective tool in ensuring that procedures are written and revised consistently

for all parts of the maintenance organization.

The effort to standardize

procedures is in the beginning stages. A large number of Instrumentation and

Control (1&C) procedures that had come due for biennial review were being revised

to the new standard.

A dedicated licensee individual in the procedure control

organization with a QA background was working with maintenance personnel to

improve procedures in general.

Communication of maintenance problems through site engineering for potential

corporate engineering assistance is accomplished through a formal procedure,

1000-ADM-7314.01 Technical Functions Work Request Task request. This procedure

provides instructions.for site engineering to request corporate. assistance for

maintenance problems.

The team reviewed three recent TFWR's from plant

engineering.

The response from corporate engineering appeared to be a thorough

I

review of the problem. Corrective action was specified through generation of

modification packages or calculations.

The team also reviewed Administrative Procedure AP-1054 Control of Environmentally

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Qualified (EQ) Safety Related Equipment.

This procedure specified a-comprehensive

plan to ensure that maintenance on EQ items does not degrado system performance.

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Responsibilities.for maintenance. management was clearly specified. . In addition,

(-

the GMS-Il system appeared to be a valuable tool for controlling maintenance on

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items with a design lifetime less than the remaining plant lifetime.

Conclusion

The team concluded that adequate communication existed between the maintenance

._

. organization and'other site / corporate entities.

Corporate policies relating

I

to procedures are delineated in procedures, and a significant effort is underway

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to. upgrade maintenance procedures.

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2.3.2 Engineering Support

Scope

The objective of this part of the inspection was to evaluate the extent to

which engineering principles and evaluations are integrated into the maintenance

process. This was accomplished by reviewing jot' orders, engineering evaluation

, requests, and other maintenance activities to evaluate the effectiveness of

engineering support.

Findinos

The site engineering group provides the primary day to day technical support

for maintenance activities. The primary vehicle for enlisting engineering

support is the engineering evaluation request (EER) which is used by the plant

materiel department personnel to request solutions to a variety of engineering

problems.

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Plant Engineering Procedure, PEP-3, is the controlling document for this

activity. The team reviewed the procedure and its implementation for

maintenance activities.

Several deficiencies were ncted in the administrative

processing of individual EER's.

The inspector was unable to locate several

EER's that had been processed during the 1986 time frame. The EER's had been

routed through the Qh department for review, which was completed. The original

EER was ~ not returned to plant engineering but was hand-carried to the

maintenance personnel for use.

Copies of the EER's in question were eventually

located in job ticket packages by plant maintenance personnel.

It appeared to the team, based on these examples and also review of the EER

logs maintained by plant engineering that hand-carried EER's were not properly

routed and controlled as required by PEP-3. Additionally, the licensee had

noted in a recently' issued quality deficiency report QDR-J0M-043-88, that EER use

was not properly implemented in that maintenance work was completed prior to

the completion of the EER routing and disposition.

Recent changes to PEP-3 and the routing ' control off EER's has contributed to

better control of EER's at the present time.

A review of the EFD backlog

revealed that the licensee's number of open EER's was almost double the goal

established.

It was noted that the onsite engineering ~ staff is somewhat

overloaded with work in this area.

The control of EER's for plant maintenance

work was considered to be a weak area in the overall maintenan'ce program.

Conclusions

Engineering support for plant maintenance activities is well documented but it

appears that the site staff is unable to properly administer the EER requests

received.

2.3.3

Licensee Acknowledgement of Risk Significance in the Maintenance

Process

Scope

The objective of this part of the inspection was to determine the extent to

which risk assessment methodology-is considered in the maintenance program

insofar as preventive maintenance, work' priority and planning / scheduling are

concerned. The team reviewed licensee activities and conducted interviews

with appropriate personnel to assess performance in this area.

Findings

TMI-1 has a state-of-the-art Level I Probabilistic Risk Assessment (PRA) that

was provided to the NRC for information in December 1987. The PRA ranks various

plant systems and accident scenarios in terms of. estimated contribution to core

melt. The licensee has factored this information, as well as other sources of

risk assessment information, into a recently developed reliability-centered

maintenance (RCM) program. This program is described in the TMI-1 Maintenance

Plan (Administrative Procedure 1070) and uses a decision-tree logic approach to

recommer.d changes to the preventive maintenance program.

This approach

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analyzes the maintenance requirements of complex equipment or systems according

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to the consequences of each failure possibility and the inherent reliability

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characteristics of each item. The process defines the functionally significant

6

items in each system or. component,-identifies the dominant failure modes for

each of those. items and recommends maintenance tasks that can cost effectively

i

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prevent the failures or reduce their likelihood. This process can.also be used

to reduce the frequency of or eliminate maintenance that is not beneficial to

+

reliability or.even deter.imental. At.the time of the inspection, rigorous RCM

analyses had been completed, and recommendations made on three systems. Those

systems are main feedwater, condensate and condensate polishing and main steam.

,

So far this program has resulted in measures to improve system reliability and,

therefore, safety. For example, additional filters were installed in the

instrument air system when a specific failure mechanism involving resin fines

was in the feedwater system. Additionally, the main feedwater pump differentail

pressure switches were replaced with a different model because of repetitive

calibration drift. The teams assessment is that RCM program nas already

demonstrated safety and reliability benefits and should be continued.

Analyses-

of approximately twelve additional systems were-scheduled for 1990.

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Conclusion

The licensee has initiated an aggressive program to improve their preventive

!

maintenance program, as well as other aspects'of maintenance, on the basis of

risk assessment information.

The team considers this to be a very worthwhile

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effort from a safety standpoint.

2.3,4 Quality Control in the Maintenance Process

[

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Scope

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The objective of this part of the inspection was to evaluate the role 'of-

quality control activities in support of maintenance, including establishing

criteria fcr inspection and implementing hold witness points. Additionally,

verification of methodology for reporting, trending and correcting quality

deficiencies was evaluated.

!

Findings

,

The licensee maintains an active Quality Control (QC) organization.

Recent

'

reorganization of the QA department on. site has resulted in a consolidation of

the QC function into one section.

Previous QA engineering (now abolished). has

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been factored into the normal maintenance support QC function. This has

resulted in a QC organization that-has the functions of: QC inspections, pro-

'

cedure review, and QA monitoring of maintenance activities. This monitoring

function was previously part of the operations monitoring function of the QA

department.

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QC inspections are established and accomplished by basically three separate

methods.

The first is the procedure review activity. All maintenance pro-

cedures, preventive / corrective, are reviewed by the QC procedure reviewers.

Then, through previously established criteria, hold / witness points are included

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in these procedures-as required.

The QC department is beginning to use the PRA

and reliability centered maintenance (RCM) reviews to focus attention on im-

portant systems / components.

Secondly, QC personnel review the weekly maintenance

work schedule to establish an inspection plan.

This plan is used for the

scheduling of the following weeks activities.

Priority for inspection of

maintenance activities that are nuclear safety related, EQ related, or have

experienced previous problems based on trend reports,.is established in'this

planning document.. As a third level, the QC monitoring personnel may select

activities to inspect as needed, based on activities in progress.

The licensee-has established procedures for reporting quality deficiencies

(QDR) and material nonconformances (MNCR).

These procedures were comprehensive

documents that adequately established systems for identification, documentation,

reporting and' correcting deficiencies.' The inspector reviewed several recently

issued QDR's that specified corrective action. The corrective action for these

QDR's was reviewed and appeared to correct the identified problems.

QDR's and other deficiencies'are trended at two separate levels. A formal

quarterly Quality Assurance Trend Analysis Report is generated for various

quality indicators' such as QDR's, MNCR's, and audit findings. These reports

are useful for long range objectives such as determining overall performance.

On a short term basis, the QC department trends minor deficiencies, by organiza-

tion, as they are identified on Quality Assurance Monitoring Reports and Plant

Inspection Reports.

These trend reports can then be reviewed to establish-

corrective action more readily than through the use of long range type numerical

trending. This system appeared to be a very useful tool in correcting adverse

trends early.

Audits of the Plant Material Department are performec' on a biennial basis. The

two previous audits in 1986 and 1988 were reviewed.

Both audits contained

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significant findings that were subsequently corrected. In most cases, these

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audits appeared to be comprehensive evaluations of the maintenance process.

Corrective action for these audits was tracked to completion by.the QA depart-

ment.

Conclusions

.

The QC involvement in maintenance activities is well documented and adequately

implemented.

Effective procedures have been established and trending of

deficiencies is accomplished at various levels. Audits of the Plant Material

Department were generally considered to be of good quality.

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2.3.5 Integration of Radiological Controls Into Maintenance Activities

[

Scope

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'The purpose of this part of the inspection was to determine the extent to w'hich

radiological control practices, including exposure minimization (ALARA), are

incorporated into maintenance activities. This included incorporation of such

^

practices into the maintenance procedures, planning for new installations and

plant modifications, and routine major and minor. maintenance activities,

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Findings

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A system is in place to ensure that plant procedures, including nonradiological

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controls procedures, are reviewed by Radiological Engineering when appropriate.

This system applies to procedure revisions as well as to newly developed pro-

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cedures. The basis of the system is a matrix that lists all TMI-1 procedures

!

by title and owner and indicates who should review the procedure before it is

'

adopted. The matrix is periodically updated by Radiological Engineering.

The-

procedure coordinator indicates on each revised procedure the reviews specified

by the matrix for.that procedure. -This procedure then goes to the Chairman of-

the Plant Review Group (PRG) for final determination of the appropriate reviewers.

The decision to send a procedure to Radiological Engineering is determined by

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the nature of the revision.

If the initial review indicates no radiological

implications, it is not sent for radiological review. Otherwise, the procedure-

is sent for review, and any comments must be resolved before the procedure. is

,

approved. The PRG Chairman also decides on the need for' radiological-review

when a new procedure is developed.

Discussions with licensee personne1'and

,

review of documentation and sample maintenance procedures that had been reviewed

by radiological controls indicated that the system works well.

Projects involvi_ng major modifications or design changes are subjected to

radiological reviews at several stages before implementation of the project.

The project engineer is required by procedure to review the project for inclusion

of ALARA measures.

A guide is provided to assist the engineer.

The guide is

!

called "ALARA Guidelines For Configuration Changes." The guide provides

3

descriptions of various ALARA techniques and checklists to help the engineer

>

identify possible dose saving measures at the design stage of the project.1 The

project engineer is also required to hold meetings to discuss the project when

the project is about 20% completa and again when it is about 80% complete.

The

meetings are required to be attended by Radiological- Engineering if the project

,

has any. radiological implications. Upon completion of the job package, it is

.

turned over to Maintenance, Construction' and Facilities (MC&F). MC&F then sends-

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the package for final review by Radiological Engineering if appropriate.

The

f,inal stage of review occurs at'the time of generation of the Radiation Work

Permit (RWP) where an ALARA review accompanies the RWP if required. Discussions

with the radiological engineers on site indicated that they were well aware of

this review process. The discussions also indicated that the processtis effective

in ensuring the participation of Radiological Engineering in important radiological

decisions. Job = tickets issued for relatively small projects are site functions

coordinated by the Maintenance department. These jobs also undergo a review

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process that includes Radiological Engineering when appropriate. A memo from

Radiological Engineering to maintenance provides guidelines for deciding whether

a job needs Radiological Engineering review. A final review for all jobs occurs

at the RWP writing stage. At that point Radiological Controls Field Operations

reviews the RWP request and job package and if necessary will send it to

Radiological Engineering for further review.

According to procedure, any RWP

estimated to exceed 5 man-rem requires and ALARA review.

One of the recent contributions by Radiological Engineering to maintenance

procedures was incorporation of measures to minimize the introduction of cobalt

alloys into the primary system during valve maintenance jobs. Maintenance _

activities and projects incorporate a cobalt reduction program in which justifi-

cation-is required-for use of specific alloys in the system of concern. .This

requirement is described in the " Cobalt Reduction Standard" issued by the

Technical Functions Division.

This standard lists the systems to which the

requirement applies and includes the reactor coolant system and any system that

discharges into that system. The standard requires that the_ responsible engineer

identify the locations of any high cobalt alloy component used in the project

and provide a written justification for its use. Measures implemented in this

ALARA effort include a gradual replacement of fuel asseubly spacer grids, and

the use of high pH primary water chemistry.

Dose reduction efforts during work in the radiologically controlled areas in-

cludes a pre-job briefing by the job supervisor. The supervi'. ors use a check

.

list to go through the items that need to be covered during the briefing.

Isometric diagrams of various areas of the plant are used in conjunction with a

laser disc video system to help workers become familiar with the work areas and

the locations of the components they are to work on before they enter the area.

Efforts are also made to rapidly repair components that contribute to contamination,

such as leaks in valves and other components.

Permanent scaffolding is being

installed at high maintenance dose locations such as the steam generator manways

and the reactor coolant pump seal areas.

Mockup training is also used to train

workers on high exposure jubs. A computer data base has recently been placed

in operation that contains maintenance histories of all components in the plant.

The system may be used to identify those components that have historically

required excessive maintenance.

However, the system does not include radiation

exposure data on these maintenance activities and cannot search for troublesome

components from the ALARA point of view.

The licensee stated that this feature

may be incorporated into the system at a future date. The licensee also stated

that this kind of search is done to some extent based on the experience of the

individual maintenance supervisors and radiological engineers _who review the

maintenance work orders for these components.

The licensee has also made

significant efforts to learn from the experiences of other reactor facilities

before undertaking major new jobs or modifications.

A dose tracking system is in use to track the dose accumulated by each depart-

ment and to compare these doses to the departmental goals.

Monthly reports are

sent to the station director, and the report is increased to' weekly during

outages.

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The system in use by the licensee to control and minimize radiation exposures

,

during maintenance activities appears to function well. A review of the

exposure rates at various locations of the plant, such as at and inside the

steam generators, the reactor coolant pumps, the refueling floor, and other

' areas shows that these exposure rates are not substantially lower than those

i

found in many plants of similar design. Nevertheless, the station achieves

relatively low annual collective doses, typically in the range of 250 person-

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rem does reduction during outage years. A shortcoming in the program is that

many of the dose reduction activities that are being routinely implemented are

.

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not described in procedures. Therefore, their continued implementation and

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success is dependent on the aggressiveness of the current staff in pursuing the

goal of minimizing exposures.

For example, procedures call for ALARA reviews

to be performed whenever the estimated dose for the job exceeds 5 person-rem.

However, the licensee stated that they routinely write ALARA reviews for jobs

with estimates above 1 person-rem. A review of the RWPs for the past year

showed that virtually all the ALARA reviews generated for that year were for

1

jobs with collective doses much lower then 5 person-rem. The licensee also

routinely performs ALARA reviews for all jobs in high radiation areas even-

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though this is not required by procedure.

Conclusion

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A review of the area of incorporation of radiation exposure reduction efforts

into maintenance activities showed that the licensee has developed a set of

measures to ensure that ALARA considerations are incorporated into all work-

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activities. The program appears to be effective .in maintaining exposures on

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site at a level that is towards the lower end of collective exposures observed

in the nuclear power industry for reactors of similar size and design,

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2.3.6 Safety Review of Maintenance Activities

,

Scope

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The objective of this part of the inspection was to evaluate the licensee

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integration of safety measures into the maintenance process, such as hazardous

'

material control, fire protection, electrical safety practices and control of

inert atmospheres.

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Findings

The~ application of measures to ensure safe performance of maintenance

activities is controlled primarily by the site safety and industria1 hygiene

department. Various safety practices for maintenance activities are controlled

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by procedures for asbestos control, confined spaces, nonradiological

'

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respiratory protection, heat stress, and electrical protection. ' These

procedures were comprehensive and incorporate applicable OSHA-requirements.

.

The asbestos control program has been particularly well . implemented at TMI.

The team observed extensive use of temporary containments in the turbine

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building where asbestos insulation removal work was in progress.- A review

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of asbestos, sampling records revealed a comprehensive sampling and' analysis

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. program to ensure that protective equipment was used when necessary.

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Use of temporary scaffolding'is adequately controlled in most cases. Scaffolding

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structures that were observed, were clear of safety related equipment or mounted

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in such a fashion as to prevent movement.

A hardhat and safety glasses policy

l

was in force and appeared to be enforced by frequent tours by safety department

personnel.

Conclusion

An adequate safety program is implemented at TMI. A safety culture is promoted.

'

at all levels of the site organizations, as evidenced by low accident rates and

a generally clean appearance of plant spaces.

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2.3.7 Integration of Regulatory Documents-into the Maintenance Process

'

scope

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The objective of this part of the inspection was to determine the methods used

'[

to integrate regulatory documents in the maintenance process and to change these

documents as a result of periodic reviews and updates.

'

Findings

,

Regulatory documents such as-information notices and general letters are initially

i

processed by the Licensing Department in accordance with a corporate procedure

and tracked as licensing actions items (LAIs). Applicable documents requiring

<

action are forwarded by licensing engineers to various site organizations for

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resolution.

A sampling of commitments shows that'the responsibility for' resolution of

various items is clearly assigned.

Personnel assigned these items were aware

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of their responsibilities and management was aware of-the status of each item.

The team review of previously closed items indicated'a generally adequate level

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of review, although the documentation provided in many LAI packages was

minimal.

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The team reviewed five items that were assigned to the maintenance department.

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These consisted of information notices and generic letters that required some

action on the part of licensee personnel.

The reviews appeared complete and

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several work items were generated as a result of the reviews. A thorough

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review of Information Notice 88-43 resulted in the replacement of. solenoid

valves for MS-V-13 A/B which control steam flow-to the steam driven emergency

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feedwater pump.

Review of Information Notice 88-12 resulted in changes to an

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' electrical preventive maintenance procedure for greasing motor operated valves,

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Conclusions

Overall control of regulatory documents was considered effective.

Reviews were

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adequate and corrective actions that resulted from the reviews accomplished

several changes to equipment or procedures for safety related systems. Although

more information could have been provided in closeout packages, the information

was generally sufficient to document the scope of review..

3.0 Maintenance Implementation

Scope

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The purpose of this part of the inspection was to determine the effectiveness

of the established maintenance controls and, more importantly, the quality of

work performed. The controls established in four areas were evaluated: Work

Control, Plant Maintenance Organization, Maintenance Facilities Equipment and

Materials Controls and Personnel Control. The team evaluated effectiveness

through discussions with all levels of personnel, observation of work in

progress, a review of completed work orders, procedures, and other documentation

associated with maintenance and training of maintenance personnel. The control

or spare parts and tool were also reviewed.

3.1 Work Control

Scope

The purpose of this area is to evaluate the effectiveness of the maintenance

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work control process to assure that plant safety, operability, and reliability

I

are maintained. Areas evaluated by the team included review of work in progress,

,

control of work orders, equipment maintenance records, job planning,

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prioritization of work, scheduling of work, control of maintenance backlog,

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maintenance procedures, post maintenance testing, and completed documentation.

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3.1.1

Review of Maintenance in Progress

(a) Mechanical

Scope

This area was reviewed to determine the extent to which mechanical maintenance

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is performed in accordance with maintenance procedures, administrative policies,

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and management goals and objectives. Where possible, maintenance activities

were reviewed from the~ preparation of the work order to final completion of the

task.

The review was conducted through observation of work in progress, review

of documentation, and discussions with workers, supervisors, and management.

Findings

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The team observed maintenance jobs in progress and jobs that were initiated

during the inspection period. The work observed had properly reviewed work

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packages available which were organized and prepared in accordance with

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applicable procedures. Workers were knowledgeable of the work to be performed,

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competent in their performance of the work, and an appropriate level of

'

supervision was evident which included engineering support where appropriate.

The following specific tasks were reviewed in detail:

-Weld repair to a highly corrosion resistant stainless steel 3/4 inch

schedule 40 pipe.

'

The task was performed under job order No.16583.

The work performed

>

included grinding out an imperfection prior.to the performance of a

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weld repair.

Further disassembly of an adjacent flange and the removal-

,

of a valve diaphragm to prevent overheating was also necessary. The

team verified the work was performed in accordance with the applicable

,

controls. The team verified proper weld filler metal withdrawal and

the posting of a fire watch. . Adequate post maintenance testing was

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specified.

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-Diaphragm replacement on valve to WDG-V-95A performed under job order

>

00016572. The team observed maintenance workers remove and replace the

valve diaphragm. The supplied replacement diaphragm was found to be the

'

incorrect size (3/4 inch vs the required 1 inch).

Technicians were

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knowledgeable of the procedure for obtaining the proper diaphragm and for

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returning the incorrect diaphragm.

Steps were taken to feed back to planners

the information necessary to make changes to stock numbers.

The procedure in use, the radiation work permit (RWP) and material

,

certificates were correct and located at the work site. Technicians

exhibited a good understanding of.the principles of radiation. controls

,

and were observed to comply with the requirements of the RWP.

Post

maintenance testing was performed satisfactorily.

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-Examination and cleaning of a Sarco strainer on the waste gas compressor

was observed by the team.

The task was performed in accordance with a

properly reviewed and approved job order, and preventive maintenance

procedure.

RWP requirements were verified to be complied with. - Although

the vendor manual was referenced in the procedure there was no need for it

'

at the work site as no strainer repairs or replacement was necessary,

'

Adequate post maintenance testing was specified.

-The team observed portions of main steam safety valve setpoint verification.

The verification was performed in accordance with a reviewed and approved

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procedure.

The procedure was. adequate to perform the task, the personnel

involved were briefed prior to the performance of the work, and performed

their assigned work in a workmanlike manner.

The initial preparation,

equipment, and instrument setup was observed.

The Hydroset equipment was

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provided by a vendor, the team reviewed calibration data and calculations

necessary to determine correct valve setpoints. Test prerequisites were

verified to have been performed.

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.No deficiencies were identified with the tests: witnessed by the team.

The "as found" setpoints were within the technical specification,

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requirements.- Some setpoint adjustment was necessary to comply with

'

the procedurally required.setpoints.- . Adequate engineering support

was provided during the conduct of the testing. A one day postponement

of the testing occurred due to-conservatism on the part of operations'

,

to verify compliance with technical specifications during the performance

of the testing. A close overview of maintenance activities by operations

was noted.

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-The: team observed the annual inspection of the "A" emergency. diesel-

-generator in accordance with surveillance procedure 1301.8.2.

The-work--

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documentation was very detailed, ~ proper. authorizations were granted prior

to the-start of the work.and the use of appropriate technical manuals was.

evident.

The-work area was maintained orderly during the work and the

personnel assigned had proper. training and qualifications.

The work'was

scheduled around the clock and the inspection was completed and the diesel

tested well before the technical specification seven: day-limitation

.'

expired.

The team specifically witnessed disassembly of' cylinders, replacement

of fuel injectors, the condition-of the removed fuel oil, and the

condition.of the fuel strainers. Also examined by the-team were the

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crankshaft and connecting rod bearings,'and the cylinder walls.- -

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(b) Electrical and' Instrumentation and Control

Scope

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-The.te'am observed plant maintenance group electricians _ perform electrical-

modifications to the "A" emergency diesel generator control panel and. relay

_

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modifications to the 4,160 volt switchgear protective relay panelL for the

generator.

The inspectors also observed performance'of electrical preventive

maintenance work including calibration testing of diesel generator protective

relays by the LeM,on Relay Division of Metropolitan Edison. _ As part. of:these

observations, tb inspectors checked to see that the work in progress was

_

properly scheduled'on _the weekly work schedule and properly authorized to start

by the Operations Department as required in plant administrative-procedures.

.

Findings

The electricians involved in the work observed by the team were knowledgeable

. . .

regarding the tasks to which they were assigned and were following the work

"

procedures explicitly in all cases. The control panel modification performed

-under. task CW-422 included a shutdown reset circuit, emergency signal test

<

lights-and elimination of a sneak circuit. -Although a detailed matrix was -

1

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provided in the work. document to ensure proper disconnection and reconnection

'

Lof'the wiring, the overall format of the work document, with a major revision

and several' attachments, was very difficult to follow and understand.

Since

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this package was prepared as a modification, its format differed from that of

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routine maintenance procedures.

To overcome the difficulty with the package, a

detailed review was performed by supervisors with the personnel who would be

conducting the work prior to its being performed.

!

This_ work was performed prior to-the start of the outage and was scheduled on

the weekly schedule to be performed throughout' the week of December 4,1989.

In fact, the work was accomplished on the day shifts on December 4-6, 1989.

Scheduling for this work performed prior- to the outage was less precise than

for that which was _ performed during the outage. Work scheduling during the

ourage was noted to be very precise,

j

All work procedures reviewed had received proper review and authorization.

Housekeeping and cleanliness were maintained during the course of the work.

Qualified test equipment and tools we're used and instrument numbers and

calibration ~ dates were properly recorded in- the work documents.-

l

The team reviewed use of the clearance-control document required by Administrative

procedure (AP) 1002 to release work under various switching and tagging orders.

The procedure provides for using an existing red tag series for work on the

same -system or component if-the existing tags provide the required isolation

for personnel safety and as long as the task or work request is entered on the

clearance control document each time clearance to work is granted and each time

i

work is stopped, such as at the end of a shift.

The team noted that no specific

'

line entries' had been made to grant clearance for the electrical'modif.ication

work performed under task CW-422. When this fact was questioned, the licensee

3

personnel supervising the work stated that this work was covered under-the

i

annual inspection of the "A" emergency diesel generator. After additional

1

review of this matter, the team concluded that administrative control of the

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electrical modification work was not in compliance with AP-1002 and considered

this failure to follow a procedure to be a violation (50-289/89-82-01). A review.

!

of other clearance control documents did not identify similar concerns although

other minor discrepancies were'noted.en various tagout application forms such

as missing dates and times, missing work document numbers and inadequate

.

descriptions of the work to be done.

Licensee management recognized the need

{

for improvement in documentation.

'

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Conclusion

i

The inspectors concluded that maintenance work is performed in a controlled

I

manner using detailed work procedures, is adequately reviewed and authorized

and is performed by qualified craftsmen under the close supervision of

experienced, conscientious supervisors.

The one violation which was noted is

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not considered to be indicative of a poor tagging program.

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3.1.2

Work Order Control

i

Scope

'

The team reviewed the process for generating work orders including the format,

4

generation mechanics, tracking system, accessibility to plant personnel,

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prioritization, identification of system classification, special processes and

qualifications, quality control and clarity of work instructions. This review

included interviews with appropriate plant personnel.

Findings

Generation of. work orders is governed primarily by Corrective Maintenance

Procedure CMP-1407-1,.and AP-1070, TMI-1 Maintenance Plan.

Both of these

procedures are well-written and understandable . A computerized system,

Generation Maintenance System 2-(GMS-2) has been implemented during-the past-

year at TMI-1 and computer generated work documents has been in use for the

past several months. Virtually all plant personnel have access to this system

and can initiate work documents or at least identify needed work.

Relevant

system / component information such as quality and _ safety classification, seismic

category and past maintenance history is programmed into GMS-2 and is available

to the user. The team considers the implementation of the GMS-2 system to be a

-

strength, although a number of implementation problems,-including system'down

times, are still being resolved. The work document format is comprehensive-and

includes appropriate review and authorizations.

TMI-1 makes extensive use of generic work procedures for both preventive-and

corrective maintenance. Although this approach has merit and reduces the

burden on personnel generating work-documents, it can sometimes place an

inordinate burden on the worker.

For example, a single work document might

consist of a computer generated cover sheet, and generic procedures for valve

repair, loosening and tightening mechanical fittings, and determining proper

torque values. The worker must determine which portion of these- generic

procedures apply on the basis of the work description on the cover sheet.

There is the potential _for misunderstanding between the: job initiator and.the

work group if specific instructions are not contained in_the work document,

either on the cover sheet or on a mark-up of the generic procedures. -Procedure

CMP 1407-1 states that the technician performing the work is to decide which

steps do not apply and insert the notation "N/A".

The procedure also states

that supervision will review the technician's decisions after the_ work is

completed.

Supervisory review 'after work completion could result in.a work

scope / sequence different from that intended-by the work document initiator.

.

The extensive use of ' generic procedure without specific instructions providing

guidance as to which specific portions are applicable is considered to be a

weakness.

The team noted a discrepancy between procedures CMP 1407-1 and AP 1001A, Review

of Generic Procedures. CMP 1407-1 states that non generic procedures will

receive the same level of review and approval as generic procedures.

However,

Table 1 of AP 1001A excludes review requirements for maintenance procedures

written for only one specific job ticket (non generic procedures). This

discrepancy was brought to the attention of the licensee personnel responsible

for these procedures.

The licensee indicated that quality assurance had identified

a related deficiency and that a procedure change request has been initiated-

which will correct this discrepancy. The team verified this change is in the

review cycle.

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. Plant procedures provide for performing " emergency work" without procedures as

long as documentation is generated after-the-fact.

This provision has rarely

been used.in he past and the rapid _ capability of GMS-2 should make it even less

l

frequent in the future. . The team considers the controls provided over.

,

emergency work to be adequate.

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'

Conclusion'

,

.The plant procedures and GMS-2 system are comprehensive and allow for expeditious

L

generation of well-formatted and understandable work orders. Although-the

system had been in operation a relatively short time, licensee personnel appeared

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comfortable and competent in using it.

Other very, positive attributes of GMS-

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!

2 are discussed elsewhere in this report.-.Although the procedures governing

this activity are well-written, the extensive use of generic procedures without-

i

indicating the applicable portions of the generic procedure is considered a

weakness.

3.1.3 E_quipment Records'and History

Scope

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The team reviewed procedures and processes for recording, tracking and utilizing

.

historical maintenance records for plant equipment. This review included

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interviews with appropriate licensee personnel as well as review of completed

I

work documentation. Among the attributes reviewed were timeliness of documenting.

,

maintenance history data, the quality and completeness of the information, use

L

of the history for trending equipment performt.nce and determination and recording

root causes of failure's.

Findings

l

The foundation of the maintenance history process is the licens'ee's GMS-2 system.

A major effort was required during 1989 to enter maintenance' history data on a

component-by-component basis into the system.

This data is now readily available

to anyone at any GMS-2 terminal in a number of formats. The team selected a

number of components on the basis of knowledge of past maintenance problems and

asked the licensee to display the history on the GMS-2. The display provided

detailed and accurate history for those components.

Root cause analyses of

I

failures, where known, were properly included in the GMS-2 data base.

Entry of

current maintenance history was found to be very timely, generally within about

,'-

one week of-work completion. The system is effectively used by planners,

engineers, work group personnel, managerial, and operations personnel.

Conclusion

The team found that TMI-1 has an effective state-of-the-art computerized system-

for maintenance history records and that the system is widely utilized by

personnel in several disciplines because of its accessibility and accuracy.

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3,1.4 - Job Planning

,

Scope

The team observed maintenance. activities, reviewed planning documents including

the weekly work schedule and interviewed personnel involved in job planning.

A-

number of work orders were also reviewed.

Findings

TheETMI-1 Planning-and. Scheduling department is well staffed with experienced

personnel who have had field experience.- There are separate sections within

the department .for long-range and short-term: planning.

The planners work-

closely with,the craft supervisors and conduct walkdowns, when appropriate', to

ensure that the job planning takes into account the physical layout of the work'

area.

Efforts are made to identify special. skills and . supporting tasks,-such

.

'as erection of scaffolds or_ enclosures. .A large amount of. pertinent information

has been programmed into.the GMS-2 system on a component-by-component basis-to

aid in accurate job planning. Meckups are fabricated' for: critical tasks such

as steam generator tube plugging and installation of_ cold leg dams.

_

Conclusions

The team concluded that appropriate procedures and controls.have been implemented

to ensure that maintenance tasks ~ are appropriately planned and coordinated.

Walkdowns are conducted on major work items and the specialiqualifications and

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training are specified. Mockup training:is conducted, when' appropriate to

train workers and reduce radiation-exposure during actual conduct- of the work.

!

. The personnel assigned _ to planning are generally former craftsmen who have-had

'

field experience in power; plant maintenance.

3 1.5 Work Prioritization

.

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Scope

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The team evaluated the effectiveness of work prioritizai. ion to determine if

I'

sefety influences the priority assigned to maintenance tasks.

The review

included work schedules, work orders and discussions with planning and scheduling

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personnel.

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Findings

.l

The licensee's procedures require assigning a numerical priority level to each!

corrective maintenance work order indicating its relevance.in terms of plant-

1

safety and effect on plant operation. The priority assignments are used in

work' scheduling and and also give the operations Shift Supervisor an indication.

of the relative importance of the work.

A review of the corrective and preventive

-)

maintenance' work backlog indicated that relatively few priority .1,

2 or 3 jobs:

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.were outstanding. The licensee has initiated a reliability centered maintenance

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program-(RCM) for developing preventive maintenance.

The RCM program utilizes

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a decision tree logic approach to analyze the maintenance requirements of

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complex equipment or systems according to the_consecuences of each failure

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possibility. The system provides useful information to assist in establishing.

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priorities- for preventive maintenance. An RCM analysis has been performed on '

.

three- systems with twelve more systems to be analyzed during the next year.

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The Quality Control inspectors also use the results of the RCM to establish

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which jobs they will monitor.

.

Conclusions

The team concluded that the procedures' at TMI-1 for prioritizing work takes

l-

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into account the-safety. significance of the equipment involved.

The licensee's

efforts in the area of reliability-centered maintenance incorporates input from

the probabilistic risk assessment as well as past maintenance history on a

system by system basis.

Excellent efforts were made during the-November 1989

unplanned outage to accomplish the highest pr.iority corrective maintenance

prior to startup.

3.1.6 Maintenance Work Scheduling

Scope

The team reviewed the effectiveness of work scheduling _in terms of utilizing

the prioritization information, avoiding work group and spatial conflicts,

coordinating the correct numbers and types of craftsmen and minimizing

"

radiation exposure.

,

Findings

.

The weekly work schedules for the weeks of December 4,1989 and January 22,

1990 were reviewed by the team.

The schedules reflected a high degree of

preplanning and contained detailed information regarding lead work group,

support crafts, priority, work location, QC coverage, RWP Requirements and job

ticket age. Observation of work in progress confirmed .the presence of

supervision and support personnel. No conflicts or work stoppages were

observed. A_special effort was made to avoid scheduling too:much work in the

D ring area of the containment building.

The_ team observed several critical

tasks in progress simultaneously in the same area and all' jobs were noted to

1

be actively working without interference. .The licensee also assigned shift

coordinators to each shift during the refueling outage as an effort to-avoid

or expeditiously resolve work conflicts.

The team observed pre-task work

group briefings and judged.them to be effective.

Conclusions

.The team concluded that scheduling and supervision of corrective and preventive

maintenance is accomplished in a reasonable and effective manner.

Effective

efforts were employed during the outage to avoid spatial conflicts in the D

ring area within the containment building. The licensee also assigned a manage-

ment shift coordinator to each shift during the outage to assure effective

coordination of the various work efforts in progress.

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3.1.7 Backlog Controls

-Scope

The team reviewed the licensee's goals and actual performance related to

controllingandmanagingthebacklogofpreventiveandcorrectivemaintenance-

K

tasks. The licensee s philosophy regarding deferral of maintenance, programs

for predictive' maintenance and the ratio of corrective maintenance.to: preventive

maintenance were all considered during this review.- Appropriate licensee

personnel were interviewed and documents pertaining to backlog controls were:

reviewed.

"

Findings-

.The inspection in this. area was conducted just prior to commencement of ~a

refueling outage af ter an extended (335 day) operating period at full power. . .

Of the 1100 ready-to work tasks, 86% were preventive maintenance tasks'and 14%-

.were corrective maintenance tasks. A review of the age of the tasks on,the

corrective mainterance backlog indicated'that 65% had been identified-during.

the past 90 days and 15% were one year or older.

The licensee' issues a. job status report weekly .that- tabulates;al1 backlog items

~

by status, craft'and reason for hold. This report is used by licensee

]

management to trend-backlog status and to schedule! backlog items - The status

'

report also lists the number of backlog tasks:in- each priority category. The

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team noted that 2 tasks in the priority 1 and 2 categories were on the' backlog-

list.

1

The licensee plans to reduce the backlog to the lowest possible level during

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the ongoing refueling outage. The backlog at the time of the inspection was <

well below licensee-established goals.

!

Conclusion

.The licensee has an. established process for tracking and managing the maintenance

backlog-

The ratio of corrective to preventive maintenance indicates an

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effective preventative maintenance program. Outstanding maintenance tasks are

prioritized according to safety and operational significance and scheduled to

be worked accordingly.

Very .few backlog items were in the higher priority

categories. The team noted that realistic backlog goals had been established-

- and quarterly updates indicated that the actual backlog was well; below the-

. goal s . .

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3.1.8 Maintenance Procedures

q

Scope

The team reviewed the process, procedures, and format established by the Llicensee

to generate maintenance procedures.

A sampling of maintenance procadures was

also reviewed to verify compliance with the process.

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Findings

At the time of the inspection, the licensee was in a transition from hand generated

to computer generated work orders, therefore the applicable administrative

procedures had instructions for both types.

Instructions'for developing _

maintenance procedures are contained in Administrative Procedure AP-1001A,-.

Procedure Review and Approval _; AP-11010,-Procedure Preparation, AP-1070, TMI-I

Maintenance Plan; AP-1101K, Biennial Procedure Review and CMP-1407-1, Unit 1,

.

General Corrective Maintenance.

The procedures are very detailed and clearly

i

denote personnel responsibilities including level of review and approval.

- Large-scale use:is made of generic procedures for corrective and preventive /

maintenance without indicating the applicable portions of the general procedure.

The format used for writing maintenance procedure's is logical and used consistently.

Good use is made of cautions, warnings and notes. -Diagrams, data sheets and

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tables are used where appropriate. Virtually all procedures and procedure

changes used for maintenance are reviewed by the.. Plant Review Group, which is

!

comprised of a number of senior, knowledgeable individuals. The maintenance

procedures provide spaces to record calibration data and serial numbers for

measuring devices and calibrated tools used for the work.

Provisions are

included for double verification', where appropriate.

Controls exist to ensure

i

that the correct revision to the procedure is used for the work.' The procedures

I

reviewed were technically correct and many had been revised to reflect lessons

learned from performance of the procedure.

In addition, each procedure is

,

required to be reviewed every two years.

!

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Conclusion

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The maintenance procedures in use at TMI-1 are of high quality and are controlled

by detailed administrative requirements.

Review and approval of these procedures

u

occurs at a high management level.

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3.1.9 Post Maintenance Testing

Scope

The purpose of this element was to verify that post maintenance testing (PMT)

criteria have been established, documented, and implemented. -Areas inspected

included licensee procedures, work in progress, completed work packages, and

discussions with personnel.

Findings

'

The licensee's requirements associated with PMT are specified in corrective

maintenance procedure 1407-1, Unit ~1 General Corrective Maintenance Procedure.

This procedure provides guidance to all personnel in the performance of maintenance

using the GMS-2 system. The guidance provided in the procedure for describing

the PMT to be performed is very general.

This lack of specific guidance for

the identification of PMT has been recognized by the licensee _and a draft

procedure 1407-8, Post Maintenance Testing, is currently in the review process.

The purpose of this new procedure is to

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provide detailed guidelines for selecting and documenting PMT following the

performance of corrective or preventive maintenance.

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The job order forms used to implement maintenance. provide for the determination

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that PMT:is required, the identification of the PMT. which is to be performed,

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and the documentation of-the PMT which-was performed. A review of job orders

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in progress, as well as completed job ~ orders, shows that occasionally the PMT

'

which is.to be performed is.not clearly specified and on other occasions the

PMT_which was performed is not clearly documented.

These deficiencies were-

discussed with maintenance group personnel which included both foremen.and-

higher management.

Results of these discussions and a review of equipment

maintenance histories shows that the need for PMT is understood and-is being

,

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performed. The deficiency-lies in the occasional inadequate documentation of

a

both the PMT which was specified and the-PMT which was performed.

Licensee

management believes that issuance of procedure 1407-8 and the: associated changes

to procedure 1407-1 will correct this deficiency. This corrective action is

scheduled to be implemented following the completion of the present outage.

The shift supervisors role in the performance of PMT was specifically reviewed.

,

It was determined that shift supervisors understand their responsibilities to

'

ensure that appropriate PMT is performed.

This includes specifying additional

l

testing other than that which is identified _ on the job order.

l

The scheduling of PMT for which specific plant conditions are needed was

I

reviewed and found to be adequate.

l

Conclusion

The specifying of the required PMT and the identification of PMT which had.been-

performed were deficient ~in that'it was on occasion not accurately documented.

Procedures are being prepared to correct this deficiency.

<

3.1.10 Review of Completed Work Documents

Scope

This area was inspected to verify that the licensee's completed work packages

include a timely and consistent review which includes work package completeness,+

closecut, and storage. This verification was accomplished by reviewing a

number of completed work packages.

Findings

'

The licensee has established a proceduralized program for reviewing completed

work packages. The program includes a completed documentation review, and

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machinery history recording as well as information needed for enhancing future

maintenance. The work package routing, review, and storage was found-to be

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satisfactory. The closeout system requires reviewing the actions of quality

control, and the post maintenance testing. .The results of all maintenance is

an input to the GMS-2 system.

During the inspection =five completed work packages from the mechanical,

instrumentation and control, and electrical groups were reviewed. The final

licensee work package review for each of the work tasks was performed within

two to three days of the^ job completion. The packages reviewed indicate lthat

approval of the work was.obtained prior to its initiation, control was-

maintained ove'r materials used, functional testing was performed as required,

identification of'~ personnel-_ performing the work was maintained, supervisory.

overview was noted, and overall package review was conducted-by qualified

personnel. The review'_of completed work packages also verified appropriate

_

engineering involvement and the performance of 50.59 reviews when required.

In

addition, during the observation of work in progress, no anomalies were noted-

in the work packages up to the point to which they had been implemented.

Conclusion

A well managed program for the review of completed wo'rk packages has been

established. Good overview by supervision and the entry of data into the

machinery history is being accomplished.

4.0 Plant Maintenance Organization

Scope

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The objective of the inspection in this area was-to determine the effectiveness

and extent of control exercised by the maintenance organization:for maintenance

i

activities, contract maintenance personnel, deficiency' identification and

control, and maintenance trending.

4.1 Control of Plant Maintenance Activities

=

Scope

The inspection of this area was to determine the extent _of established controls

for the performance of maintenance activities and to verify-that these controls

have been properly implemented in the mechanical, electrical, and instrumentation

1

and control disciplines.

The inspection consisted of a review of. documents,

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interviews with craftsmen, supervisors and managers as well as the observation'

l

of work in progress, the supervision of the work, the degree of adherence to

established controls, and tours of the physical facilities for each department.

a.

Mechanical Maintenance

.,

The licensee has established procedures for determining the need for corrective

r

preventive and emergency maintenance. Maintenance procedures provide for

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identifying tasks, planning, scheduling, and performance monitoring of

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maintenance activities.

Quarterly reports of reviews of the proceeding twelve

months maintenance history are prepared to identify trendL :n the numbers of

failures experienced, and to identify areas requiring futW a attention.

Attention during these reviews is directed down to the component level, and

preventive maintenance is scheduled to increase reliability.

Improvements in

proceduren where indicated, are also initiated.

Work activities are reviewed at the foreman level prior to implementation

for the assignment of appropriately trained and ;ualified personnel. The

training records for maintenance personnel are readily available and are

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. utilized. Training records for mechanics performing the~ diesel generator work

were reviewed and it was verified that they were appropriately qualified.

Personnel observed performing maintenance. reflected a-good working knowledge

of the work being performed, a familiarity with the equipment and the

procedures.

Pre-job briefings by supervisors were effective in-establishing

the overall effectiveness of the workers.

Observations and discussions'with

maintenance personnel indicates controls and procedures are effectively

~

implemented.

Supervisor. involvement was clearly evident and cooperation with a

vendor representative was excellent.

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Maintenance planners frequently designate the use of- generic procedures in the

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work packages. A number of these procedures were reviewed and found.to be

satisfactory.

Certain concerns associated with the use of gener.ic procedures

are discussed in another section of this report.

A weakness was identified in' the control of vendor technical manuals.

l

Procedure P1065, Vendor Document Control, addresses vendor manuals, drawings,

and bulletins. A licensee audit of vendor technical manuals in early 1989

indicated that 30 manuals of approximately 2000 controlled manuals had been

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lost or misplaced. The audit' period encompassed the four years that- procedure

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AP 1065 was in effect. Also, during this in.spection a number of vendor

manuals were identified which were not entered into the vendor manual control

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program. The control of new vendor documents entered into the

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program appeared to be satisfactory.

!

b.

Electrical and Instrumentation and Control (I&C) Maintenance

i

Findings

. Personnel in both departments.take pride in their workmanship and the high

a

standard to which the electrical and I&C systems are maintained.

The craftsmen /

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technicians are highly qualified and trained in their areas of expertise,

j

Instruments and special tools are controlled and calibrated as required. The

-)

individuals contacted considered that they have effective lines of communication

to management to suggest improvements in the maintenance programs.and that

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management is interested in hearing what they have to say.

The team observed a

1

number of instances of such communications during the inspection. All levels

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of supervision and management are actively engaged in overview of work in

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progress.and are readily accessible when not actually at the job site in case

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-difficulties arise. .The workers and first-line supervisors ensure the current

,

revisions of work procedures and manuals are being used Lfor the work. As~

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previously discussed the practice of not marking non-applicable portions of

work procedures ' place this burden on the worker and does not require supervisory

,

review.until after the workLis completed.' The I&C department has the capability-

'

of calibrating high accuracy test gages on-site.

This is a benefit in that it -

improves on-site understanding-of the sensitivity'and limitations of these

instruments.

Conclusion

,

The team concluded that adequate control and excellent supervision exists for

maintenance work performed by mechanical, electrical and I&C departments.

Established administrative controls are followed and initiative to apply the

sk(lls of the trade is.also encouraged within the' structure of the work

procedures. The' staff is competent' and highly trained.

The problem identified

s

with the control of vendor manuals is not indicative of a deficient work

control program.

1

'4.2

Control of Contracted Maintenance

.

Scope

>

Inspection in this area was.to-verify that controls are established to ensure-

that maintenance work performed by contractors is adequately. performed and -

verified. The inspection was performed through a review of training records,

I

completed job tickets, discussions with personnel and.the observation of work

being performed by contractors.

Findings

Contractors performing maintenance at TMI-1 are, to the extent possible,

selected from a list.of workers who had previously worked at the site.

The

majority of the contractors performing maintenance during this outage come

from the Pennsylvania Electric Company, Metropolitan Edison Company, and

l

several contractors who provide. trained instrumentation and controls (I&C)

!

technicians. Contractors are required to comply with GPUN's training-

L

requirements; security requirements, which includes psychological screening,;

and the fitness for duty policy.

Each contractor is required to complete.a qualification evaluation which

includes a pre-hire checklist to identify the skills and training which they

.

possess. . Training which is to be provided, is based'on the results of these

. check-lists as well as the tasks the contractors are scheduled to perform.

General employee training, radiation worker, administrative procedure, and

procedure usage training are routinely provided each contractor.

In addition,

each lead group supervisor determines the tasks which are to be performed-by

contractor personnel, and determines the specific training required based on

these tasks. This specific training consists of completing the licensee's

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on-the-job (DJT) training.

OJT consists of both classroom and practical training

i

as_well as the completion of qualification cards.

Examples of the type of

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training provided are breaker overhaul, valve packing, and reactor head removal

training.

I&C technicians are not trained on specific tasks but are required

.to review a number of procedures. The training received by each contractor is-

documented.

4

All work by contractors is performed in accordance with the job ticket system:

which assures the use of the correct procedures and the proper documentation of

the work performed. All work by contractors is performed-along with GPUN

personnel or supervised by GPUN personnel. GPUN supervision was apparent for

the work: observed being performed by contractors.

The requirements associated with the control and training of contractors is

currently being implemented informally through verbal directives from management.

The licensee indicated a procedure.will be prepared which will formally describe

the controls to be exercised for contractors.

Quality _ assurance personnel maintain a cognizance of the work being performed

by contractors and schedule increased surveillance of this work.

Conclusion

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The selection, qualification evaluation, training, and supervision of contractors

is adequate to assure quality work is performed. A-procedure will be developed

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to formally describe contractor controls.

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4.3 Deficiency Identification and Control

4

Scope

t

Inspection of this area was conducted to evaluate the licensee's system for

i

identifying both physical deficiencies in-the facility as well as deficiencies

in the conduct of maintenance activities. The evaluation was-conducted

through a review of procedures, documentation, and discussion- with' personnel.

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Findings

.

The primary means of identifying material deficiencies in the plant is the

'

Unit 1 General Corrective Maintenance Procedure 1407-1.

Using this procedure

any person may identify a condition which requires maintenance.- The.use of

j

this procedure is described ~1n other sections of this report. Two other

i

methods established for the identification and correction of deficiencies

identified in the plant are GPUN Qualit? ueficiency Reports, and GPUN material

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nonconformance reports. The use of bota t'ese methods is-described in the.

i

corporate policy and procedure manual.

A review of records shows both these

systems are being used

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The role of quality assurance in the identification of deficiencies in the

conduct of maintenance activities was specifically evaluated. The TMI-1

Quality Assurance.1989 Annual Assessment was reviewed. -This review determined

that QA has monitored the use of maintenance procedures, maintenance work

practices, and the integration of the GMS-2 system. ' Deficiencies which_were

noted were called to management's attention.

Also, QA/QC findings were

trended to assist management in determining areas.which require added

attention.

-A positive-initiative in the identification'of deficiencies associated with

maintenance-_ activities-included'the performance of: reviews by QA of the

maintenance planning process, and the data associated with the annual

-

inspection;of the_ emergency diesel generators. .Both these reviews were

performed at the request of maintenance management. A number of deficiencies

were identified which' indicate a- need for increased management attention in

certain areas. 'An example included the many deficiencies that were identified-

which dealt with deficient documentation.

The action taken by management to-

initiate the QA reviews is an indication that improvement in the control of

maintenance is desired, and that use is being made of the QA group to' identify

deficient areas.

Actions taken by management to correct the deficiencies which were identified

had not yet been taken and consequently could not be reviewed.

In response to some previously identified deficient areas the licensee is

working on improving the quality of biennial procedure reviews,.and has

prepared a new procedure writers guide to assist in the preparation of

improved procedures.

Conclusion

Methods have been established for the identification of deficiencies.

{

Maintenance management is using the QA groups expertise to assist in the

identification of deficient areas.

Steps have been taken to improve the

!

quality of procedures.

Improvement is warranted in the documentation of.

certain maintenance activities.

!

4.4 Performance of Maintenance Trending

The intent of this element was to determine, by reviewing completed work and

i

equipment records, that trending of system / component failures is proceduralized,

accomplished and' documented. Additionally, the maintenance program was reviewed

for evidence of root cause analysis, self assessment / performance indicators and

rework evaluations.

Findings

The licensee Plant Materiel Department accomplishes trending of maintenance,

deficiencies / problems and incorporate root cause analysis in determining

actual failure mechanisms.

Maintenance trending is proceduralized in General

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Maintenance Procedure 1407-3, Assessment of the Adequacy of the Preventive

Maintenance Program.

This procedure specifie; periodic assessment of the

preventive maintenance program. - Quarterly reports are generated based on

input from the GMS-2 system.. Based on inputs from the " Corrective Maintenance

Component History Report" when three or more failures occur on any individual

component a Maintenance Trend Action Notice is generated.

This notice

requires action-from organizations, such as operations or site engineering to

'

recommend. corrective measures. The team reviewed several of these MTANs to

verify that corrective action was appropriately implemented.

Root cause analysis is performed'using the Kepner-Tregoe method.

This

analysis technique is proceduralized in General Maintenance procedure 1407-6,

Root Cause Investigation.

This procedure is invoked based on management discretion.

1

The team reviewed several recently completed analyses and reviews that are still

in progress. The analyses were adequate in that the solutions generated appear.

to have prevented reoccurrence of the problem. Although there is no specific

guidance this analysis technique:has been directed at a variety of component

failures that directly affect safe operation.

The licensee does not have a-specific re-work evaluation procedure or systematic

approach. The team noted that based on a limited review of completed corrective

maintenance and discussions with management, that re-work did not appear to be

a problem.

Conclusions

The team determined that the licensee maintains an adequately documented and

implemented maintenance trending program.

Root cause analyses is incorporated'

into this process. The team concluded that re-work was not a significant

problem in the licensee maintenance program.

4.5 Establish Support Interfaces

i

Scope

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The intent of this portion of the inspection was to determine if the

'

maintenance organization had established an active interface for information

transfer and problem solution with support organizations such as engineering,

quality control, operations, safety, and radiological- controls.

Findings

The team found that the Plant Materiel Department maintains an adequate

interface with other site organizations. The primary mechanism for this is

regular daily planning meetings which are attended by virtually all site

organizations.. At the meeting, each item on the active work list is discussed,

and a determination made if assistance is needed from other site organizations.

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The Plant Materiel Department communicates to both plant engineering and

operations, various concerns, thru the maintenance trend analysis reports

(MTAN). These reports require response to the material assessment manager for

. resolution of identified problems.

The team viewed MTANs as an effective method of

solving maintenance related. problems.

The GMS-2 system was effective in

- tracking these items.

Quality control (QC) is actively involved in the maintenance-process. The

weekly planning / scheduling' document is reviewed by QC personnel to establish

- an overall inspection schedule for the following week.

Engineering support for in progress work is communicated formally through the

Engineering Evaluation Request (EER)., The use of these EERs as well as the

individual engineers cognizance of important main.tenance activities indicates

good engineering / maintenance interfaces are-being maintained.

Maintenance procedure reviews are accomplished by both radiological, engineering

~

and quality control (QC) personnel. QC review is accomplished for all procedures.

This typ af interface ensures that appropriate QC and radiological control

considerations are proceduralized prior.to work accomplishment.

Conclusions

The team concluded that the Plant Materiel Department maintains an adequate

interface with site organizations. Maintenance task reviews, frequent meetings

f

and various methods of requesting assistance were' adequately proceduralized and

!

implemented.

5.0 Maintenance Facilities. Equipment and Materials Control

The objective of the inspection in this area was to assess,the plant's. maintenance

facilities and controls ove" maintenance equipment, tools', and materials to

determine how well these elements support maintenance work. The team evaluated

the following areas during this inspection:

control of maintenance facilities

and equipment, establishment of material controls, establishment of maintenance

.<

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tool controls, and control of measuring and test equipment.

5.1 Maintenance Facilities and-Equipment

Scope

The purpose of this element was to inspect the extent to which the plant

,'

facilities and equipment provided by the licensee enhance the maintenance

process. This area was evaluated through interviews with personnel, tours of

,

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the plant, offices, and shops.

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Findings

4

Physical facilities are provided to support maintenance activities. Supervisors

offices are generally located adjacent to the work areas.

Supervisor presence

in the shop areas was notec.

The machine . shop was clean and equipment. arranged

in an orderly manner.

The instrument shop was observed to be untidy at the-

beginning of the inspection, however, steps were taken during the inspection to

improve its appearance

The existing instrument shop, adjacent to the control

room, is too small to support the 33 technicians employed' This has been-

recognized by the licensee and steps are currently being.taken to provide-

~ additional instrument and electrical shop areas.

A small instrument shop will

be maintained adjacent to the control room in order to maintain close support

to operations.

Hot shops (instrument a '

ochanical) are.provided as 6re

contaminated tool storage facilities. A n w fabrication shop is also under

construction to provide space for work curtently being performed on the lower

level of the turbine building.

In addition to the shops, tools, and spaces already provided to support maintenance,

the licensee is evaluating additional programs and equipment. These programs

and equipment are intended to assist in diagnosing equipment conditions and

to enhance the-planning of preventive maintenance. Among these are a lubrication

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program which ensures lubrication tasks are accomplished, oil samples are-

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obtained, results evaluated, and follow-up action taken, when required.

Oil

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sampling-for 41 pieces of equipment is specified.

'

A thermography program which has been in place since 1984, is performed

semiannually by a contractor,and is being expanded. A purchase order has been

written to obtain thermographic equipment and measures are being initiated to

perform this work in-house. The Optalign program _(for verifying large rotating

equipment alignment) is being expanded, although some procedures and training

is still needed. A vibration analysis program'is in place.

This program obtains

and trends vibration readings on most pieces of running equipment on a weekly

basis.

Some formalization of this program is still needed A functioning stand

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for balancing rotating equipment is also-available. A structured program for

testing electrolytic capacitors is being finalimt, and a state-of-the-art

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capacitor-inductor analyzer has been purchased t(support this program.

A plant

performance analysis system, and a Turbomac system for the' diagnosis of large

!

rotating equipment are under evaluation

' Discussions with personnel indicate a

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strong interest in the evaluation of additional diagnostic equipment,

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Conclusion

The licensee has taken steps to improve the physical facilities when the need

was evident. A number of plant improvements are currently under construction.

!

Good programs such as the lubrication program are available to ensure proper

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maintenance of equipment.

A good vibration analysis program is in place, some

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-diagnostic equipment has been procured and additional equipment is being

evaluated. Some effort is still needed to formalize the' implementation of

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certain programs.

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5.2 Material Controls

scope

The purpose of this element was to review the licensee's' material controls in

- their support'of the maintenance process. Areas inspected included warehouse

activities and material _ storage areas in the plant as well as procedures which

govern-these activities.

Fi nd_i ng s'

Policies and procedures _have been established for the procurement storage and-

issuance of materials.

Certain TMI warehouse procedures were reviewed and a-

tour of the warehouse and material storage areas were conducted. Guidelines

reviewed are adequate to ensure timely procurement of material, documentation,

testing, and traceability of records.

Three QC inspectors are designated as:

full time receipt inspectors.

Provisions have been established:for expediting

emergency procurements. Acceptable procurement sources and the number of

~

spares to be' maintained have been identified._ Designated storage areas have-

been provided for flammable and hazardous materials.-

The warehouse has an inplace shelf life procedure.- The team verified that-

measures are being taken to ensure shelf life control.

'A. warehouse cleanliness

and housekeeping procedure has been issued which outlines requirements.for

wareh_ouse storage areas.

This procedure' specifies. periodic. inspections of-the

storage areas be performed.

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During a tour of the warehouse, it was noted some valves in> storage were not

capped as recommended by the licensee's procedure and also certain; snubbers -

were stored in a manner which could cause-damage.

It appears that during the.

required warehouse' inspections, more attention is needed to verify the . require-

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ments of the cleanliness and. housekeeping procedure:as'well as adherence to

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procedures for the general storage of-material. The deficiencies identified in

the storage of materials in the warehouse along with the required inspections

not identifying the problem is considered to be a weakness.

4

The in plant storage of equipment in shop areas, which is to be conducted in

accordance'with Corrective Maintenance-Procedure 1407-1, was also inspected.

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Storage areas associated with mechanical, el?ctrical, and-instrument and. controls

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were inspected. Certain deficiencies were noted during this inspection. These

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deficiencies are identified as follows. _The-in plant storage procedure requires

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storage areas be mair.tained in accordance with ANSI.N45.2.2. This statement

provides little guir'ance to personnel since workers in.volved with this procedure

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are not familiar with ANSI N45.2.2. .0ther def.iciencies noted include access to

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storage areas is non always controlled, Q listed items, tools and non Q spare

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parts are frequently stored together, shelf' 11fe material is stored _in such a

manner that the expiration date could not be determined because it-had.been

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removed from its original packaging.and material which had been removed from

the plant was not tagged as required.

The failure to control access, _ as well

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as the failure to identify the shelf life expiration date and the improper

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tagging of material removed from the plant are considered to be violations

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(50-289/89-82-02) to Unit 1 General Corrective Maintenance Procedure 1407-1,

Enclosure 4, In-Plant StoraSe of Equipment in Shop Areas.

As a further review of this area, it was noted that QDR HRH-027-89 issued on

May 12, 1989, identified almost identical concerns. -Likewise earlier QAMR's

(HRH-0505-88, 0505A-88 and 0505B-88) also identified similar deficiencies. The

lack of-appropriate corrective action taken in response to negative QA findings

in this area is considered to be a weakness.

Conclusion

The licensee has. adequate procedures and controls which address the procurement and

storage of spare parts and materials.

The improper storage of certain materials

in the warehouse was identified as a weakness,

Likewise, the in plant storage-

of equipment'in the shop. areas was not conducted in accordance with procedural

requirements.

Improvement is needed in the (mplementation of corrective actions

taken in response to similar deficiencies identified by QA.

5.3 Establishment of Maintenance Tool and Equipment Control

Scope

The purpose of this element was.to determine the extent to which tool and

- - -

equipment control has been documented and implemented and to assess its support

of the maintenance process. This area was evaluated-through interviews with

personnel, review of documentation and observation of work and storage areas.

Findings

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The licensee's controls established for the maintenance of wire rope and

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synthetic slings, and hand operated hoisting equipment was reviewed.

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Maintenance procedure 1408-6, Inspection of Wire Rope or Synthetic Slings, is

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intended.to provide guidance for the inspection prior to each use of slings

constructed of wire rope or synthetic webbing.

The licensee's control of slings was reviewed through discussions with personnel,

inspections of slings, sling storage areas, and observation of slingstin use.

Results of this review indicate that, although.the purpose of the procedure is-

to provide a sling inspection prior to each use, these inspections are not always

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accomplished as recommended by the procedure. The individual-who issues slings

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does not perform an inspection nor do the sling' users. No sling inspections are

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documented, and no periodic inspections are required. One inspection criteria

specified by the procedure is " elongation exceeding manufactures recommendations."

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Neither the procedure originator, the procedure owner, nor the personnel

providing training in this area knew how this procedural requirement was to be

implemented.

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Slings are identified by tags as requireo and are generally adequately stored -

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and maintained. Although during a tour, one wire and one synthetic sling which

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did not meet specified requirements for sling condition were observed. These.

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slings were discarded.

A contractor who is permanently on site also maintains -

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a number of slings, but no inspection criteria are' specified for these slings;

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Unit 2 has a sling inspection program and slings transferred from Unit.2 have

inspection expiration date tags attached._

A. number of these' inspection dates

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were noted to have been exceeded.

The sling inspection' procedure is considered to be deficient in that itt

(a)-

does not specify a formal sling inspection period and associated documentation;

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(b') does not include any inspection requirements for slings issued by a contractor;

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and (c) includes inspection criteria with which no one is familiar._-These

~ deficiencies in the procedure are considered to~ be a weakness in the procedure

review process which did not identify these deficiencies.

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The licensee's control of hand operated- hoisting equipment was also inspected.

Licensee procedure 1408-5, Testing'and Inspection of Hand Operated Hoisting

Equipment describes the performance of testing, pre-test inspections, load

testing of equipment, and post-test inspections.

The record requirements

associated with the testing is;also specified.

The procedure does not specify

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the frequency for the performance of testing and on-site: testing in accordance-

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with the procedure is not accomplisned.

In general', the licensee.has no formal'

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program for the inspection and certification of hand operated hoisting

equipment,

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The records associated with four hand operated hoists were reviewed to determine

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the attention given.to this equipment. 0f the four pieces of equipment- selected,

two had certified inspections performed by-a vendor but no dates were indicated.

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One had a certified inspection performed in 1986 and-one was certified in 1984

and again in 1986. Two hand operated' hoists were'also noted by the team to be

tagged indicating they were to be sent out for repair. Discussions-with personnel

indicate on site testing would only be' accomplished if maintenance were' performed.

Visual inspections are performed prior to use and deficiencies are repaired off

site. Additionally, a' contractor on site also has a number.of hand operated

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hoists. No provisions exist for the -certification of this equipment.

The hoist manufacturers instructions recommend that the equipment be inspected

in accordance with American National Standard ANSI B30.16. The requirements of

this standard are not reflected in the licensee's hand operated hoisting :

equipment procedure.

The fact that the licensee's periodic review of the hand operated' hoisting

equipment procedure did not identify certain conditions is considered to be a

weakness. Conditions not identified included:

the controls'exerciseduover the

equipment are different than that specified by the procedure; the control of

contractor controlled equipment is not specified and the inspections recommended

by the ANSI standard are not included in the procedure.

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Conclusion

Slings and hand. operated hoisting equipment are generally used by knowledgeable

people who perform visual-inspections of the equipment prior to its use. The

procedures associated with this equipment reflect the lack of a thorough periodic

review. The procedures are deficient in a number of areas noted above. The

deficiencies were not identified during their biennial reviews.

5.4 Control and Calibration of Metering'and Test Equipment

Scope

The purpose of this. inspection area was to determine the extent to which meters

and test equipment.are control' led and calibrated. This area was inspected

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through discussions with personnel, inspection of instruments, and instrument

storage areas, and a review of records.

Findings

The licensee has a detailed Administrative Procedure AP-1022, Control of

Measuring and Test Equipment, which establishes the requirements and defines

the responsibilities for the control of measuring and test equipment (M&TE).

-The implementation of certain requirements of this procedure were reviewed.

The electrical, mechanical, and instrumentation and control (I&C) groups each

maintain their own supply of M&TE in designated storage areas.

The procedure.

requires that each piece of M&TE be uniquely identified. The team verified

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that this was accomplished.

M&lE storage areas were generally well maintained, although significant

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differences in the ability-to. locate a particular piece of equipment were noted

among the different groups. The I&C. group was by far the best organized.

Although designated storage areas were provided, some electrical test instruments

were stored outside the designated areas.

The procedure specifies that an inventory be maintained of M&TE by each group.

}

The inventory is accomplished differently by each group, and varies from a

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simple list to calibration data sheets-for each item. serving as the inventory.

With the exception of the I&C group, the inventories required by the procedure

contain some errors and were not kept current.

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Calibration records were being maintained for each piece of equipment selected

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for review.

Each piece:of equipment reviewed had-prescribed calibration

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frequencies specified, was in calibration, and was . appropriately labeled to

.

indicate.the calibration due date.

Damaged or out of calibration equipment was

also clearly identified.

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The procedure specifies that M&TE will be issued only to authorized personnel.

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M&TE is not actually issued per se, but is chacked out by individuals who are

expected to complete a test equipment usage card each time the instruroent is

used. With the exception of the I&C group, some problems were noted with the

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use of instrument usage cards.

For example, during the inspection, two pieces __

of electrical test instrumentation were found out of the storage area but not.

signed out on the usage card as required.. Also, one instrument has been out

for approximately one month even though the procedure requires a usage- card be

filled out for each separate job. 'Likewise, the mechanical group had four

torque wrenches which were missing with no usage cards completed as required.

_

Also, one torque wrench was noted to have been out for over one month.

During

the attempt to locate the four torque wrenches, it was determined that during

the past two years 31 torque-wrenches had been designated as missing. The

failure to complete test equipment usage cards as required is considered to be

a violation (50-289/89-02-03).

During a QA audit, S-TMI-88-01 performed January 20 through March 10, 1988, a

similar finding dealing with the completion of-usage cards associated with

_

micrometers was noted. The failure to take effective. corrective action -to this-

QA finding dealing with usage cards is considered to be a weakness.

Although deficiencies were noted in the implementation of the control of M&TE

procedure licenses personnel appear to be aware of the need for using properly

controlled and calibrated equipment on safety related tasks.

Conclusion

An adequate procedure has been provided to control M&TE. An ample supply of

calibrated test equipment appears to be available. However, -implementation'of

the procedure needs to be improved particularly in the maintaining of equipment

inventory and the preparation of- equipment usage cards. .The team was concerned

that similar problems had been identified by QA and adequate corrective action'

was not taken.

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6.0 Personnel Control

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The objective of the . inspection in this area was to determine the extent to

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which personnel-are trained and qualified to perform maintenance activities,

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In assessing this area,.the inspectors examined staffing control, training,

testing and qualification, and current status. The teams' evaluation was

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based on interviews, direct observations of the training facility and field

)

activities, and reviews of records.

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Findings

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Staffing at the facility is relatively stable.

The normal progression to

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supervisory positions is through promotion from the bargaining unit.

Tests are.

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administered prior to promoting personnel.

Up to date organization charts are

available as are job descriptions and schedules designating work periods and

time allotted for training. The supervisor to worker ratio varies among the

groups and shifts; however, the overall average is one to five.

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The turnover rate is approximately three persons per year from a complement of

about 190.

This is due to generally competitive salaries and benefits, careful

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screening of new hires, and an attempt to hire individuals who have lived in

.

the area..

The licensee performs both corrective and preventive u.aintenance on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

per day basis.

Instrument and control, mechanical, and electrical. workers are

assigned to each shift. Maintenance workers on each shift are available for-

emergency maintenance, if required.

Overtime is not _normally scheduled but is;

worked as needed. Overall, overtime is maintained at' less that 15%. The

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maintenance staff is increased by about 100 during' refueling. <These workers

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are to the extent possible selected and come from the Pennsylvania Electric

Company, TMI Unit 2, and other Metropolitan Edison Company facilities,

GPUN has an INPO accredited training and qualification program,. Maintenance-.

training is provided by a maintenance training group within the training depart--

ment. This group consists of a manager and seven additional personnel _ devoted

primarily to maintenance personnel training. -The training requirements for

individuals within the maintenance department is determined by the performance

of a job analysis which identified training requirements relative to job tasks.

- The job analysis is performed in accordance with a specific procedure.

TMI-1 maintenance training is specified in training department procedure

7814-PGD-2662, TMI-1 Maintenance Training and Qualification Program. The

training provided is based on each trades job analysis and the needs of

specific individuals as determined from pre-hire check sheets and a training

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needs evaluation, as specified by the procedure.

Training is divided into initial training, continuing training, and specialized

training.

The initial training. consists of approximately three weeks of-

maintenance indoctrination training, followed by fundamental-_ training and

on-the-job training (0JT). The fundamental training consists of_ classroom

instruction and practical training and is a five to ten week program. The OJT

is provided after the completion of the fundamentals training and provides-

classroom training in accordance with specific lesson plans _and-also practical

training using training aids.

Provisions are _ included for the waiving of

training for individuals already possessing certain skills.

Cyclic continuing training is provided for each trade as determined by a

Maintenance Technical Center Review and Interface Group.

Examples of-this

training are industrial experience ~ review, general employee training, emergency

plan training, and plant equipment or system modification training.

Specialized. training is provided for individuals who perform unique, highly

specialized, tasks. ' Examples are control rod drives, integrated control system

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and vibration analysis training.

The training procedure. included requirements

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for instructor qualification and certification, as well as requirements for

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evaluators attending an OJT evaluation course.

Provisions are included for

instructor performance evaluation,

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' Training evaluation is accomplished through bath written evaluation (minimum-

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acceptable grade 70%) and OJT performance evaluation against criteria

established for each OJT qualification card.

Training records are maintained

'

by both the training department and the maintenance department.

Certain specific training department procedures have been prepared.

Examples

of these procedures are 6210-ADM-2600.07, Plant Equipment / System Change or-

Ad_ditions Review for Training.

This procedure defines.the training department

method for the identification, assignment, and tracking of TMI-plant

equipment / system' changes or modifications, and 6210-ADM-2600.04, Incorporating.

Industry Experience into Training Programs.

Training aids, used for the practical exercises described by the program, are

currently stored and used in four trailers on site. An existing building is

s

currently being remodeled. This building will provide permanent space for the

maintenance and use of training aids.

Discussions by the team with maintenance

workers indicates they feel _that a good balance between classroom instruction

and. practical exercise has been achieved.

.

The six shift rotation established for maintenance workers provides ample time

for training in that essentially one in six weeks is available for training.

This is considered to be a strength.

The licensee has-provided supervisory training for a long time; however, this-

training had not been formalized.

Currently a more formalized program for the

training of supervisors is being established.

Another program available to GPUN employees is an educational assistance-program.

This' program provides employees the opportunity toLimprove their skills and

knowledge through further education by providing financial assistance to employees

in areas of education and training which will be a mutual. benefit to the

employees and the company.

The current status of personnel training and qualifications is maintained and

readily available. Qualification records are used to assure that-work is not

performed by unqualified workers. A fitness-for-duty program is in place which

includes both GPUN and contractor personnel.

The program includes both-. drugs

and alcohol, and includes specified testing. All personnel are periodically

informed of the company's policy concerning use of alcoholic beverages and:

other' substances. Also, the licensee has a corporate program which specifies

disciplinary guidelines.

Conclusion

The licensee has a stable experienced work' force.

A six shift maintenance work-

rotation schedule has been established.which provides maintenance personnel on

site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. This rotation schedule also provides adequate time for-

training. A dedicated maintenance training group has,been established to pro-

vide the training for maintenance personnel which is determined to be necessary.

Measures have been established to determine workers training needs and facilities

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for accomodating training aids are being improved.

Super' visor training is being

performed and the program designating this training is being formalized.

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ATTACHMENT 1

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PRE-INSPECTION REQUESTED INFORMATION-

This is a copy of the attachment to the October 2, 1989 letter to the licensee

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. requesting:certain' site specific'information to be used in preparing for the

on site inspection.

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To aid-.us. In preparing for the maintenance -inspection'.please provide us with

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' the following documents, procedures and'information in accordance with the

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designated numbers.

If you do not have the requested document or information,.

it is not necessary to generate it to. comply with this request. -We recognize

that.many of the documents requested. separately may'be inclusive in'a larger

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single document.

Please provide five sets of;the requested documents.

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member of'our staff will-contactyou regarding the best method of transmitting

the documents to us.

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Section 1 - Description of' General -Plant Maintenance Activities '

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1-1 Maintenance administrative procedures which describe-your-

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corrective, preventive'and predictive maintenance activities.

1-2 . Organization charts including the maintenance organization and

plant-wide organizations.

1-3 Procedures, -charts and other documents which describe your Planning-

Department and.its activities.

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1-4 Documents which describe maintenance planning and scheduling.

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meetings and status of maintenance reports.

1-5 Documents which describe the Maintenance and-Operations interface

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during planning, scheduling, work start, work closeout and post

maintenance / functional testing.

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1-6 Documents which describe-your work control process: .how a work order

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is started, planned, executed, closed out and equipment returned to

service.

1-7 Documents which describe training and retraining of plant and

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contractor maintenance personnel.

(For maintenance activities o.nly,

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do not include GET.)

1-8 Documents which describe interfaces and communications among the

technical' support, engineering support and the maintenance /I&C

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Departments,

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1-9- Documents which describe maintenance work procedure establishment

and control: Criteria as to when a-procedure is to be used; initial

wr_iteup; reviews and approval; revisions; human factors review; QA

reviews; requirements for: conduct of~ work; troubleshooting criteria;

work closeout; post maintenance testing and restoration of systems.

1-10 Description'cf' methods by which mai_ntenance performance is'

-measured.. Are performance indicators used? What-ere they?--~_Who:is

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informed of the results?

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1-11 Description of process-_-for communications with vendors for technical ~

services and latest technical'information on equipment and systems.

. installed at the plant', and.. interfaces with vendors of NSSS for-

training, modifications and equipment replacement.-

1-12 Documents.which describe.the preventive maintenance and predictive

maintenance. programs.

Which equipment is included?.

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How is maintenance frequency determined?

What is done with results of these maintenance actions?

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1-13 Documents which describe management involvement in maintenance.

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Are there goals set for_the maintenance and I&C Departments?

Are these goals.used in the performance evaluation of managers

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and supervisors?

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Are these goals communicated to first.line supervisors and

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chiefs?

Section 2 - Status of Plant and Contractor. Personnel Who Perform Maintenance.

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2-1 -The number of craft personnel for electrical, mechanical and I&C

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maintenance organizations.

Pleasex include' foremen and foreman to

craft ratio.

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2-2 The average years of experience for each individual and the turnover

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rate.

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2-3 Description of shift work and work assignments.

How do' foremen

decide on which cr' aft is to perform what type of work?

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Section-3-- Status of Plant Equinment and' Plant Maintenance

3-1 What equipment failures occurred during the last year of operations?

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3-2 What equipment failures have been found during shutdown of plant?

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3-3 Describe maintenance and testing for diesel generators and

electrical equipment including switchgear that' would be required-in

. case of loss of offsite power.

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3_-4

What component failures present greatest risk from a- probabilistic.

risk standpoint to the plant?

3-5 What have been_the areas of-high maintenance activity.on safety

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related and non-safety related equipment and components?

3-6 ; Provide ~the following statustcon_cerning Maintenance Work Orders.

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(MWO).

Current total listing and' status of MW0s, number in planning,

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number in final ~: sign-off,' number on hold-for lack of parts,,

~ number on hold for engineering assistance, number available to -

be worked on,

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Projected number of corrective PN0s to be_ outstanding at

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start-up by priority..

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. Rate of completion of corrective MWO in terms of number

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completed / month and manhours expended (by craft)/ month for the-

past 12 months.

Current. number of preventive maintenance work orders overdue.

Rate of completion of preventive MWO for the past 12' months.

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Estimated manhours required to' complete current preventive

maintenance MW0s,

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Number MW0s requiring rework'over_past'6' months.

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3-7 Provide five corrective maintenance procedures for work'that is

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scheduled for the upcoming outage.

MOVs, PRVs, ECS Pumps,

Batteries, Switchgear, etc.

3-8 Provide.five preventive maintenance procedures that are scheduled

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for the upcoming outage.

3-9 Provide your overall outage schedule.

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ATTACHMENT 2

PERSONS ATTENDING EXIT MEETINGS

GPU Nuclear Corporation

T.G. Broughton, Director Operations and Maintenance, TMI-1

• J.J. Colitz,-Plant Engineering Director, TMI-l'

• W.D. County, TMI Site Audits

• • J.C. Fornicola, Manager,- TMI QA Modifications / Operations

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• • R.R. Harper, Manager Plant Material

• • D.V. Hassler, Licensing Engineer

• W.G. Heyser, Licensing Engineer

H.D. Hukill, Vice President ~and Director,-TMI-1

c.C. Incorvati, QC Manager

• A.J. Palmer, Radiation: Controls Field, Operations Manager

W. Popow, Special Projects Director

W Schucker, Nuclear Safety / Procedures

0. Shalikashvili, Manager Plant Training

• R.P. Shaw, Radiation Controls Director

D.M.-Shov11n, Plant. Material Director

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• • P.A. Sinegar, Administrator Plant Material

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• C.W. Smyth, TMI-1, Licensing Manager--

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• D.J. Chawaga, Radiation Specialist

• W.J. Pasciak, Chief, Facilities Radiation Protection Section

• • D. Taylor, Reactor Engineer

F.I. Young, Sr. Resident Inspector

• Attended December 15, 1989 Exit Meeting Only-

• • Attended January 25, 1990 Exit Meeting Only

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ATTACHMENT 3

SUMMARY OF WEAKNESSES *

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Weakness Description

Report Paragraph

1.

Engineering evaluation requests (EER)

2.3.2

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.not completed in accordance with applicable

plant engineering procedure. Also,

outstanding EERs almost double the goal

established.

2.

Generic procedures are frequently used in'

3.1.2

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work packages without indication as to wtich

portions of the generic procedure are

applicable to the work being performed.

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3.

A number of vendor manuals were identified

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which were not in the vendor document control

program.

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4.

Improvement is warranted in the storage of

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some material in the warehouse.

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5.

Inadequate corrective action for quality

5.2

assurance findings associated with in plant

5.4

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storage of equipment in shop areas and the

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control of test equipment,

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6.

Periodic procedure reviews did not identify

5.3

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significant deficiencies in several procedures

associated with slings and hoisting equipment

control.

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A condition presented for licensee evaluation and corrective action as

applicable,

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PRESENTATION TREE

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TREE INITIATORS

MAINTENANCE INSPECTION

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