ML20043C622

Advises That NRC Intends to Perform Team Insp of Maint Program at Plant on 900709-20

ML20043C622
Person / Time
Site:	Yankee Rowe
Issue date:	05/30/1990
From:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kadak A YANKEE ATOMIC ELECTRIC CO.
References
NUDOCS 9006050394
Download: ML20043C622 (16)

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MAY 3 0 W Docket No.50-029 Yankee Atomic Electric Company ATTN:

Dr. Andrew C. Kadak President and Chief Operating Officer 580 Main Street Bolton, Massachusetts 01740-1398 4

Gentlemen:

Subject:

Maintenance Program Team Inspection This letter is to inform you that the NRC intends to perform a team inspection of your maintenance program at the Yankee Nuclear Power Station in Rowe, Massachusetts on July 9-20, 1990 and to request your assistance in accomplishing this task.

The inspection will focus on the performance of maintenance and whether components, systems and structures of your plant are adequately maintained and properly repaired so that they are available to perform their intended safety function.

In order for us to properly prepare for the inspection and maximize the onsite time spent in observation of maintenance in progreos, ws: request that you furnish the reference material identified in Enclosure 1 to this letter.

To assist you in the gathering of the requested reference material, we have enclosed a Maintenance Inspection Tree (Enclosure 2) which is used by the team as guidance during the inspection. The team leader will be contacting a member of your staff shortly regarding the information that will be needed prior to the start of the inspection and to arrange a suitable date for a meeting to explain the inspection and assessment methodology.

A copy of the NRC Temporary Instruction 2515/97, " Maintenance Inspection,"

Revision 1 is enclosed for your information and to aid in the preparation for the inspection (Enclosure 3).

Thank you for your cooperation in this matter.

If you have any questions regarding this matter, please contact Donald Caphton, Team Leader, at (215)337-5287 or Norman Blumberg at (215) 337-5199 or myself at (215) 337-5291.

Sincerely, Original Signed By.1, ROBERT M. GALLO l

Robert M. Gallo, Chief I.

Operations Branch Division of Reactor Safety 9006050394 900530 PDR ADOCK 05000029 l \\

Q FDC y

" Yankee, Atomic Electric Co.

2

Enclosures:

1.

Request for Material 2.

Maintenance Inspection Tree 3.

NRC Temporary Instruction 2515/97 Maintenance Inspection cc w/ enc 1:

N. St. Laurent, Plant Superintendent G. Papanic, Jr., Senior Project Engineer - Licensing R. Hallisey, Dept. of Public Health, Commonwealth of Massachusetts Public Document Room (PDR)

Local Public Document Room (LPDR)

Nucler

. '-ty Information Center (hSIC)

NRC r siden

'nspector Comn anwealt of Massachusetts, SLO Designee Stats *f ermont, SLO Designee bec w/t..cli t

Region I Docket Room (with concurrences)

M. Perkins, DRMA (w/o enc 1)

M. H9dges, DRS R. Callo, DRS D. Caphton, DRS R. Bellamy, DRSS R. Blough, DRP H. Eichenholz, SRI - Vermont Yankee (w/ concurrences)

G. Grant, SRI - Vermont Yankee J. Johnson, DRP K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports J. Caldwell, NRR M. Fairtile, NRR DRS Files (3)

DRS:RI DRS:RI DR :RI 07drett Y

Taphton/ajk erg Ga lh 05/#/90 05

/90 05/p/90 0FFICIAL RECORD COPY CAPHTON/Y.A. MTl 7/9-5/24/90

ENCLOSURE 1 To aid us in the prepar& tion for the maintenance inspection, please provide us

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with certain documents, procedures, administrative controls, and information which are needed to prepare for the inspection.

We request that you provide your pertinent documents covering each of the elements on the Maintenance Inspection Tree (see Enclosure 2) to include your management and administrative controls, procedures, instructions and guides.

Experience has shown that providing the requested information in accordance with the elements on the inspection tree makes the preparation for the inspection less difficult for both yourself and the team.

If you do not have a document for any specific item within an element, it is not necessary to generate it to comply with this request.

The blocks on this tree identified as 1.0, 2.0, etc.

need not have any information provided by you.

It is recognized that some documents may be applicable to a number of elements, for these, it is only necessary to provide the document for one element and only list it for the other elements for which it also applies. Also, to aid in the planning of the onsite portion of the inspection, please provide us with the appropriate contact for each element.

In addition to the information provided in accordance with the elements on the inspection tree, to ful;y prepare for the inspection, we also request that you include, for our review, the following information. Any of the below listed information provided in accordance with the tree elements need only be listed and not separately provided.

Please provide three sets of the requested documents, A member of our staff will contact a member of your staff regarding the best method of transmitting the documents to us.

Additional Requested Information Description of methods by which maintenance performance is measured. Are performance indicators used? What are they? Who is informed of the reports that are used to assess maintenance performance.

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 equipment and NSSS vendors for training, modifi-cations, and equipment replacement.

Documents which describe the preventive maintenance and predictive maintenance programs.

Which equipment is included?

How is maintenance frequency determined?

What is done with results of these maintenance actions?

The number of craf t personnel for electrical, mechanical, and I&C maintenance organizations.

Please include foremen and the foremen to craft ratio.

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e The average years of experience for each individual and the turnover rate.

Description of shift work and work assignments.

How do licensee supervisors decide on which craft or contractor is to perform what type of work?

Identify significant equipment failures which occurred during the last two years, include those identified during the last refueling.

Describe the maintenance and testing of diesel generators and class 1E electrical equipment.

Provide the following status concerning Maintenance Work Orders (MW0s).

Current total listing and status of MW0s, number in planning, number in final sign-off, number on hold for lack of parts, number on hold for engineering assistance, number available to be worked on.

Projected number of corrective MW0s to be outstanding at start-up by priority.

Rate of completion of corrective MW0s in terms of number completed per month and manhours expended (by craft) per month for the past 12 months.

Current number of preventive maintenance work orders overdue.

Rate of completion of preventive MW0s for the past 12 months.

Estimated manhours required to complete current preventive maintenance MW0s.

Number MW0s requiring rework over the past six months.

Provide five corrective maintenance procedures for work that is scheduled for the outage (e.g., MOVs, PRVs, Solenoid Operated Valves, Safety / Relief Valves, ECS Pumps, Batteries, Switchgear, etc.)

Provide five preventive maintenance procedures that are scheduled prior to your next scheduled outage.

Provide your overall maintenance schedule for the outage, 1

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NRC INSPECTION MANUAL poEn TEMPORARY INSTRUCTION 2515/97, REVISION 1 MAINTENANCE INSPECTION 2515/97-01 PURPOSE This temporary instruction (TI) provides guidance for conducting a perfor-mance-based inspection of an established and implemented maintenance process at all operating nuclear power stations.

2515/97-02 GBJECTIVES The primary objective of this Tl is to determine whether all components, systems, and structures of nuclear powcr plants are adequately maintained so that they can be relied upon to perform their intended functions. R Additionally, this Tl should determine whether the maintenance process provides for the prompt repair of plant components, systems, and structures, as dppropriate to their prescribed functions, 2515/97-03 BACKGROUND NRC has examineo their nuclear power plant maintenance programs and has found a wide variation in their effectiveness.

Inadequate maintenance has been a significant contributor to plant and system reliability problems end, thus, is a safety concern.

Analysis of operational events has shown that nuclear power plant components 6re not being maintained at a level of reliability R commensurate with their impurtance to safety.

This Tl was ceveloped to inspect and assess the effectiveness of maintenance at selected nuclear power plant sites.

A Maintenance Inspection Tree (tree) will be used as guidance during these inspections to collate and present inspection findings.

The tree is intended to provide a systematic approach to the performance of the inspections and to ensure a level of consistency.

R 2515/97-04 CONDUCTING TEAN INSPECTIONS The maintenance team inspections will be announced when the team leader prepares for the pre-inspection visit (Section 04.01) to the site.

The full-scope inspection cycle will generally be of a 6-week duration, with the team leader possibly taking an additional 2 weeks to initially coordinate the inspection, gather information, and issue the final inspection report, issue Date:

09/22/09

I

.The fi weeks nf team ef fort should gererally consist of I weet nf preparation.

l' week of in-office inspection, I weeks of onsite inspectinn, and 2 weeks of doctimen t a t i on.

The sequence of the inspection effort will be deterrnined by I

the regional office, for example, the 2 weets of onsite inspection may be consecutive or separotrd by I week of in-of fice inspectinn.

Generally, the inspection tedm will be composed of the following six members:

one team leader (region) two reactor / project engineers (region) one radiation specialist (region) two engineers (HQ)

The team composition and/or the extent of effort for individual members nay bt adjusted by the region.

For example, the extent of involvement of the radiation specialist may be less than 6 full weeks, as determined by the regional office, in addition, the regions may include involvement of the resident inspector (RI) to the extent that is normally covered by IP-62703 monthly examinations.

The R1 should be provided training in the use of the logic tree by the appropriate team leader for this purpose.

The project manager (PH) will be generally involved with each inspection to' the following extent:

be available to the team leader to facilitate contacts with the licensee attend 1 to 2 days of the team preparation attend final pre-exit team meeting attend exit meetings The team will determine what failures of significant equipment (probabilistic R risk assessment (PRA)-identified, safety-related, or balance of plant (BOP) that af fects safety-related and special interest items) have occurred and will inspect the licensee's trending and maintenance activities to schedule, R repair, and prevent further failure of that equipment,

,0ther selective examinations of equipment failures attributed to maintenance will be examined to determine the adequacy of licensee corrective actions and root-cause detenninations of the failures. The inspection should be performed following review of the elements of the Meintenance inspection Tree (tree) and the additional inspection guidance provided in the Maintenance Inspection Guid-ance Volumes I and 11 (separately distributed).

This guidance should be used as an aid in determining adequacy and implementation of maintenance activities and to evaluate them.

The tree is also used as a tool to provide a level of uniformity in inspection structure and in the prelimina ry recording of the inspection results.

It is important to stress that the tree does not drive the inspection, but it does represent guidance in the areas of inspection to be considered in planning the scope of the inspection, with R inspection results recorded on the tree to the extent completed.

The tree consists of three major sections:

(1) Overall Plant Performance, (2) Management Support of Maintenance, and (3) Maintenance implementation.

The inspection requirements for liaintenance Inplementation, which focus on the plant systems, components, test and surveillance data, and related activities, will receive the major portion (at least 80 percent, including direct observations of maintenance being performed) of the inspection effort.

-Itsue Date:

09/22/89 251497

Eql It should be recogni; ed that irspection results frnte the Maintenance

,ltnplementation trea will clso provide input to the f4et.agement Support area.

11 is expected that portions of the Panagement Support of Maintenance

$6ctions of the tree, especially the Panagernent Conrni tmen t and Management Organization sections, cculd be conducted by a single team rnenber in a relatively short twe.

The amount of inspection ef fort devoted to the indiviaval subsections of the tree will be determined by the regional office, taking into account recent inspection findings, time and staff limitations, and future inspec-tions planned to cover specific areas.

The inspection is to determine the effectiveness of the total integrated maintenance process of the power reactor licensees.

Therefore, the team inspection may be directed into areas for which explicit regulatory require-ments may not exist.

Thus, the inspection is oriented toward analyzing the performance of maintenance activities rather than toward the identifi-cation of violations.

A specific eFample of an area not subject to explicit requirements is the licensee's participation with the Institute of Nuclear Power Operations (INPO),

Review of licensee resolution of INP0 activities shall be conducted in accordance with established policy and, thus, observa-tions in this area, when warranted, should be treated as indicators of '

strengths or weaknesses.

Although the inspection may result in the identification of inadequacies that are not covered by explicit regulatory requirements, there is no intent to

" ratchet" licensees.

Individual findings that licensees are not following published NRC guides and industry guidelines do not necessarily indicate that a program or area is inadequate.

The goal of the inspection effort is to emphasize the use of plant experience, test, reliability and surveillance R data, component failures, PRA insights (available to the licensee or provided R to the team by the Risk Applications Branch), and items of interest in evaluating the licensee's maintenance process in tems of capabilities and performance, and to identify major strengths and weaknesses as they are related to safety significance.

04.01 Team Leader Preparation.

A meeting should be held with the licensee to descrWe the scope of the inspection and to obtain preliminary review materials, such as the licensee's procedures for planning, conducting and assessing maintenance, as well as organizational charts, work schedules, equipment lists, component failure and trending data, completed work orders, R and related quality control (OC) inspection procedures.

The material obtained by the team leader from the licensee should be distributed to the team members for their review.

Following completion of the in-office review of the licensee's maintenance process, the team leader will discuss the results of these reviews with the team members and factor them into the plan for the onsite inspection.

04.02 Inspection preparation.

In preparation for site inspections, the inspection team should review the elements of the Maintenance inspection Tree to determine which areas may have received recent inspections, which areas may not be applic6ble, and which areas will be reviewed at the plant site.

The three major parts of maintenance (i.e.,

overall plant perfoma nce, management support of maintenance, and maintenance implementation) should be inspected to the degree required to provide a valid conclusion regarding the

)

ef fectiveness of the licensee's maintenance program, l

7515/W Issue Date:

09/22/89 i

d

.During the preparation phase, the team should select several conTonent s an,d/or systems for detailed irspection either throuch consideration of available PPA

insights, licens mg trending data, component failures R in safety-related or BOP systems that affect safety, or selected equipment of heightened interest to the Conrnission, such as check valves, motor-operated valves, solenoid-operated valves, and air systems.

The PRA insights may be used to select components or activities whose pottetial failures are predicted to contribute most to the risk at that plant.

At least one high-risk system should be included to verify that all performance-related maintenance has been accomplished, including preventive maintenance. Equip-R ment failures provide a vchicle for review of various aspects of maintenance, including ront-cause analysis and trending, equipment history, corrective R actions, and past maintenance (preventive or corrective).

Inspection of failed equipment repairs or work packages will provide the opportunity to examine the adequacy of the interaction of all licensee functions supporting maintenance, including engineering analyses and trending.

Review of performance indicator data, systematic assessment of licensee performance (SAlp) reports, previous inspection findings, licersee event reports (LERs), maintenance radiation exposurt history, and other direct measures inay identify potential weak areas at that plant for which more detailed inspection may be required.

Figure 1 (Inspection Flowchart) depicts the initiators that may be selected to enter the tree.

During the preparation phase, program strengths and weaknesses in certain areas may be recorded on the Maintenance inspection Tree (working tree).

If there are sufficient data to provide an evaluation rating during the prepara-tion, the elements should be rated in accordance with the Maintenance inspection Guidance.

However, selected items and, in particular, identified weaknesses should be verified ouring the onsite inspection, even if an evaluation rating is assigned during the preparation.

04.03 Onsite Inspection.

An entrance meeting shall be held with the licen-see tc detail the scope and schedule of the inspection, introduce the team members, and establish the licensee's contacts for the inspection.

The team should obtain from the licensee the status of ongoing work applicable to the inspection or that may affect the perfonnance of the inspection or the inspection schedule.

Schedules and plans for the exit meetings and the interim meetings between the team leader and licensee management should also y

be established during the entrance meeting.

L Team members shall perfonn a detailed walkdown inspection of the plant on the first or second day on site to observe the overall plant and equipment l

material condition.

This walkdown inspection, in which the team should 1

observe the condition of numerous valves, pumps, motors, etc., should include, but not be limited to the following:

a Condition of components Significance of tagged equipment Housekeeping and environment l

Adequacy of labeling Comparisons with drawings and/or procedures

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Status of annuncictors This walkdown inspection may provide indications of areas requiring further exemination during the inspection, y

Issue Date: 09/22/09 2515/97 j

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j lhc onsite inspection should f ocus on the direct observatice nf work in

progress, including the f ollowir e of licensee work wit h ecuipment in

. progress (e.9.,

tagouts, procedures, work packages, engineering support, mdterials, cennunica t ioris, testing, et,provals, civality control holdpoints, etc.), significance of the maintenance backlog, rework, licensee ass (ssment of the performance nf matntenance, work control processes, control of inter-faces, post-maintenance testing, plant material condition, and maintenance facilities.

On the basis of the collected data, the team should deteritine the apparent cause of any problems noted; that is, if the cause is related in the adecuacy of procedures, work packages, qualification of personnel, management, engineering, etc.

This analysis should provide entry into specific elements of the tree, which then becomes a tool to eFplore the suspected causes and to assess effectiveness of the implementation of applicable elements.

All areas listed need not be used in forming conclusions for cach element.

Furthermore, other areas of inspection selected by the team may be used for entry to tree elements.

04.04 Analysis.

Using the inspection findings and results noted on the Maintenance Inspection Tree, the team should determine whether each of the areas inspected has been adequately implemented by the licensee and whether or not there is enough information to assign a rating.

The Maintenance inspection Guidance and Criteria previously provided also assists use of the Maintenance inspection Tree.

elements identified en the work sheets.The team will assign a rating to the applicable The team should assign an overall evaluation rating to each of the elements inspected.

When this analysis has been completed, an overall rating can be determined in accordance with the Maintenance inspection Guidance and Criteria.

04.05 Exit Meeting.

Before the final days of inspection, issues and findings should be reduced to definitive writing and then used to highlight the presentation version of the Maintenance inspection Tree (the Presentation Tree) and to complete the rating roll-up.

The exit meeting should include a brief discussion of the preliminary inspection findings using the Presenta-tion Tree to depict inspection results in a summary fashion; however, the licensee should be informed that the findings are preliminary until they are reviewed by regional management and the inspection report is issued.

1 04.06 Report preparation.

Because of the broad extent of the inspection, documentation of inspection activities should begin early in the process to minimize the time required to complete the final report.

The final report should document the assumptions useo, the elements inspected, the elements that were not applicable, licensee strengths and weaknesses, and overall 4

conclusions consistent with IMC-0610.

The report should address elements of i

the tree to at least the depth of the tier with eight areas (e.g., Direct Measures, Management Commitment and involvement, etc. ).

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04.07 Follow Up.

Any unresolved findings identified during the inspection will be appropriately tracked and resolved by the regior.al office.

2515/97

-S-Issue Date: 09/22/89

(:

a 2515/97 05 If4 SPEC 110N Rf 0lllRf t't.fils

. ibt inspection shall include selective examinations of the aspects of main-tenance listed in Sections 05.01 through 05.03, including each of the areas related elements of lict rsee activities identified unc'er the sectior.s.

and To the extent possible, selective examinations should t'e based on observation of maintenance and equiptr.ent work activities in progress, review of licensee implementation of maintenance procedures and controls, results of review of selected do'cuments (such as work packages, equipment test results, and engi-neering evaluations), and interviews with personnel).

05.01 Overall Plant perfonnance Related to Maintenance a.

Direct Measures.

The team shall conduct a' propriate examinations of p

plant operability, equipment availatgilit,y, and plant material condition that can be directly related to the effective implementa-tion of a maintenance process.

Before conducting the inspection of plant performance, the inspector should review availabic plant information on (1) availability, (2) operability, and (3) reliability.

Information on these items can be obtained from the plant's.

operating history.

Other sources for obtaining the information are SAlp reports, Performance Indicator Data, AE00-Scram Studies, ESF Actuation Studies.

Safety System Unavailability Studies. Technical Specification Violations, Monthly Operating Peport Data, and Capacity Factors from NUREG-0020.

Data collection should be directed to those measures related to safety significant aspects of the maintenance process.

In addition, the inspector should conduct a detailed walkdown inspection of the overall plant material condition to assess the effectiveness of the licensee's maintenance process to the extent that it is reflected in plant housekeeping and in the external condition of equipment.

The scope of the inspection shculd include examination of direct measures by using information gleaned from plant and equipment for the following:

Historical data Material condition 05.02 Management Support of Maintenance a.

Management Commitment and involvement.

The examination of management effectiveness concerning maintenance should be directed to deter-mining the extent of corporate and plant management awareness and support of the maintenance and resolution of maintenance problems and should include examination of:

The application of industry initiatives.

Extent of management direct participation in maintenance and in corrective actions (management vigor and example),

b.

Management Organization and Administration.

The inspection of management organization and administration controls should be directed to determining how the organization supports maintenance activities, what maintenance activity plan has been established, how the maintenance activity plan has been implemented, corrected, and controlled, and the control of resources.

The inspection should include examination of:

J Issue Date: 09/22/89 2515/97

Progrcm coverage for maintenance i

Policy, poals, and objectives for maintenance Allocation of resources Definition of maintenance requirements i

Performance measurement Document Cnntrol System for maintenance Maintenance decision process c.

Technical _ support.

The areas that are to be selectively examined for the technical support organizations with regard to maintenance are as follows:

Internal and/or corporate communication channels Engineering control Licensee acknowledgement of risk significance R

Ouality control Incorporation cf radiological controls into maintenance process Safety Review Committees Regulatory documents Trending R

Examples of the ap this inspection are:plicable departments or organizations subject to Engineering (nuclear, instrumentation and control (180),

mechanical, electrical, licensing, systems, etc.)

Quality Assurance (0A)

Quality Control (00)

Health Physics (HP)

Sa fety Fire Protection Operatic.ns 05.03 Maintenance implementation a.

Work Control.

The inspection of the work control process should be directed to work order documentation, equipment history, observation of. testing in progress, planning and scheduling, and document review.

The inspection should incluce selective examination of:

Review of maintenance in progress Work order control Maintenance of equipment records and history

'i

• . Job planning Work prioritiration Haintenance work scheduling Backlog controls Maintenance procedures Post-maintenance testing Review of completed work control documents b.

Plant Maintenance Organization.

The inspection of the plant mainte-nance organization should be directed to how the organi'zation supports maintenance activities, how the naintenance activities are controlled, implemented, and corrected, how personnel are controlled, how ?.he organization establishes documentation, thc effectiveness of 2515/97 Issue Date: 09/22/89

the coordination and feedback lines of connunico t inn t'etween plant monagement ard craf t personriel, and the ef fectiveness of interfaces with other departments, especially operations.

The inspection shculd include selective examination of:

Control of plant maintenance activities Control of contracted maintenance Deficiency identification, control, and corrective action system Maintenance trending Support interfaces Maintenance Facilities Equipment, and Materials Control.

The fol-c.

Towing are to be selectively examined for the area of facilities, equipment, and material controls, as well as for their suppcrt of the maintenance process:

Maintenance facilities and equipment Material controls Maintenance tool and equipment control Control and calibration of measurement and test equipment d.

Personnel Control.

The following areas of personnel control are to be selectively

examined, including consideration of

staffing, training, and qualification:

Staffing control Personnel training Test and qualification process Assessment of the current personnel control status 2515/97-06 REPORTING REQUIREMENTS The appropriate regional office will document the findings and the actions taken in an inspection report and, in addition to the normal distribution, will forward one copy to the Director, Division of Licensee Performance and Quality Evaluation, Office of NRR, and one copy to the Director, Division of Reactor Safety, in each of the other regional offices. A copy of the R Maintenance inspection Tree colored to reflect the inspection results for R each inspection cenducted should be sent to the Chief of POEB at mail stop R 10-A-19.

R 2515/97-07 COMPLETION SCHEDULE Inspections should be scheduled so that they are completed prior to April, P,

1991.

2515/97-08 EXP!RATIF-,

This temporary instruction shall remain in effect until April 1991 or R until the inspections have been completed.

Issue Date:

09/22/89 2515/97

2515/97-09 NRR CONTACT

• Any questions regarding this temporery instruction should be addressed to A. T. Gody (301-492-1117).

2515/97-10 STATISTICAL DATA REPORTING Record the actual time spent to perfonn this inspection against inspection procedure number 05597 for the 766 system and 2515/097 for RITS.

2515/97-11 ORIGINATING ORGANIZATION INFORMATION 11.01 Organization Responsibilities.

The Perfonnance and Ouality Evaluation Branch of hhR will provide support and overall guidance for these insper-

tions, 11.02 Estimated Resources.

Each inspection is planned for 6 weeks for 6 persons with 2 of the 6 weeks being direct onsite inspection (12 staff weeks) and I week in-office inspection, with expected additional effort by the team leader (a total of 38 staff weeks).

This total includes prepara-tion, inspection and report writing.

11.03 Parallel Inspection Procedures The inspection procedures that this Tl may satisfy totally or in part are listed belos.

Where credit is taken, the inspection report should note the h:spection procedure number per IMC-0610.

The region should make final determinations based on the scope and documentation of the inspection.

37701 56700 62704 37702 61700 62705 37828 CIP 61725' 72701 38701' 62700 83000 series 38702 62702 92700 CIP 41400 62703 CIP 92701 END l

l 2515/97 Issuc Date: 09/22/89