ML20055G378
| ML20055G378 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/16/1990 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055G377 | List: |
| References | |
| 50-333-90-80, NUDOCS 9007230111 | |
| Download: ML20055G378 (54) | |
See also: IR 05000333/1990080
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r U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-333/90-80
License No. DPR-59
Licensee: Power Authority of the State of New York
P.O. Box 41
Lycoming, New York 13093
Facility: James A. FitzPatrick Nuclear Power Plant
Inspection at: Scriba, New York
Inspection conducted: April 16 - May 11, 1990
- Inspectors: A. Delia Greca, Senior Reactor Engineer
E. H. Gray, Senior Reactor Engineer, Team Leader
G. K. Hunegs, Resident Inspector, IP3
R. Haroldsen, Consultant - Electrical
B. E. Martin, Consultant - Mechanical
R. McBrearty, Reactor Engineer
P. V. O'Connell, Radiation Specialist
'd.- Woody, Engineering Inspector, DOE
Approved by: 4%gre f /2. A /oM f f, a
acqud'P. Durr, Chief, Engineering Branch, d e
Division'of Reactor Safety
Summary: :See Executive . Summary
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> TABLE OF' CONTENTS.
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Designation. _N_o_. - .
,, -EXECUTIVE SUMMARY...................................... 4 I
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-INTRODUCTION........................................... 7 o t
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s I '0VERALL PLANT PERFORMANCE RELATED TO MAINTENANCE....... I 9 !
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1. 0 Di rec t ' Me a s u re s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1. 0 9
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Historic Data ................................... 1.1' 9
Pl a ntl Wa l kdown In specti on ' . . . . . . . . . . . . . . . . . . . . . . . . '1. 2 9-
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II MANAGEMENT- SUPPORT OF MAINTENANCE . . . . . . . . . . . . . . . . . . . . . II 12L .
2' 0 Management Commitment end Involvement ........... 2.0 12.
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' Application of' Industry Initiatives .........-.... 2.1 12
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g Management' Vigor and Example .
........ 2.2 13
3.-0 ' Management Organizationiand Administration
- (Corporate and Plant)............................ 3.0 13
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Program' Coverage for Maintenance ............,..., 3.1 L13 ;
~f;" Establish Pelicy, Goals, and Objectives ..........-3.2- 14
Resources A11ocation............................. 3.3 14
. Maintenance Requirements ...............-.........-. 3.4 1 41
Conduct Performance Measurements ~................. 3.5 15 ,
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, Document. Control-System ......................... 3.6- '16
- Maintenance Decision Process .................... 3.7 17s
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, Support.................................-4.0 17 a
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Establish Communication Chctnels ................ 4.1 17 .
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. Engineer'ing Support'............................. 4.2 18
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~ Role of PRA in-the Maintenance Process .......... 4;3 19
Quality Control.in the Maintenance Process ...... 4.-4 20- "
Radiological Controls in the Maintenance Process . 4.5 21-
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Safety-Review of Maintenance Activities .......... 4.6- 23-
g -Regulatory Documents .in Maintenance . . . . . . . . . . . . . 4.7 24
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LIIII MAINTENANCE IMP'LEMENTATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . III 25
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5.0L Work Contro1.......................... .......... 5.0 25 i
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Maintenance in Progress .......................... 5.1 25-
Mechanical Maintenance ...... .............. 5.1.1 25
Electrical / Maintenance . . . . . . . . . . . . . . . . . . . . . 5.1.2 27
Instrumentation .& - Control s Maintenance . . . . . 5.1.3 28
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Tree Page
Designation No.
Work Order Control .............................. 5.2 29
Equipment Records and History ................... 5.3 31
Work Planning ................................... 5.4 31
Work Priorities ................................. 5.5 32
Work Scheduling ................................. 5.6 33
Ba c kl og Control s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5. 7 34
Maintenance Procedures .......................... 5.8 34
Post Maintenance Testing ........................ 5.9 35
Review of Completed Work Documents .............. 5.10 36
6.0 Plant Maintenance Organization................... 6.0 37
Control of Plant Maintenance Activities ......... 6.1 37
Mechanical Maintenance .......................... 6.1.1 37
El ectri cal Mai ntenance . . . . . . . . . . . . . . . . . . . . . . . . . . 6.1.2 38
Instrumentation & Controls Maintenance ........... 6.1'.3 39
Control of Contracted Maintenance ............... 6.2 42-
Deficiency Identification and Control ........... 6.3 43
Maintenance Trending ............................ 6.4 44
Support Inte rf ace s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6. 5 45
7.0 Maintenance Facilities, Equipment, and
Ma te ri al s Con t rol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7. 0 46
Maintenance Facilities and Equipment ............ 7.1 47
Material Controls ............................... 7.2 -47
Tool and Equipment Control . . . . . . . . . . . . . . . . . . . . . . 7. 3 48
Control and Calibration - M&TE................... 7.4 49
8.0 Personnel Contro1................................ 8.0 49
. Staffing Control ................................ 8.1 50
Personnel Training .............................. 8.2 50
Te st and Quali fication Process . . . . . . . . . . . . . . . . . . 8.3 51
Appendix 1 - Individuals Contacted
Appendix 2 - Summary of Weaknesses
Figure 1 - Maintenance Inspection Tree
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EXECUTIVE SUMMARY
An in depth team inspection of the FitzPatrick maintenance program and its
implementation was performed on April 16 - May 11, 1990. The inspection
included a review of the maintenance program and observations of maintenance
work in progress. NRC Maintenance Inspection Guidance, dated September 1988,
and Temporary Instruction 2515/97, dated September 22, 1989 were used for this
inspection.
The inspection team evaluated three major areas: (1) overall plant performance
as related to maintenance (2) management support of maintenance; and (3)
maintenance implementation. For each element, the inspectors evaluated both
the program and the effectiveness of the implementation.- The inspection results
for each area are summarized in the following paragraphs and are discussed in
' detail in Sections I, II, and III in the body of the report.
I. OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE
From initial operation until the start of the current outage, the plant has
performed with high availability factors and minimal shutdowns resulting from
inadequate maintenance. Based on historic information, it may be concluded
that maintenance was effectively implemented during the first fifteen years of..
operation.
During plant walkdowns the team noted that, in general, all plant areas have
received adequate attention relative-to good housekeeping. However,- one
situation which could be improved is the identification of equipment and plant
areas. Equipment' tags were small or hard to find; sometimes no tags could be
found. Similarly, elevations and column locations were almost nonexisten'.. .
The only item of potential safety significance identified by the team is the
hanging of instrument calibration pots on cages around instrument racks
without seismic analysis. The pots were removed prior to completion of the
inspeccion.
II. MANAGEMENT SUPPORT OF MAINTENANCE
The maintenance program at JAF is based on a plan developed in late 1984.
Written policies and guidelines identify the responsibilities for developing "
the required procedures and for performing the work. Many of the work level
procedures were observed to be of recent origin or revision. This is indicative
o'f t program which is not fully mature but also undergoing an evolutionary
process' directed to improve maintenance.
The team found management to be generally supportive of improvements in the
maintenance program. This is primac 'y evident in the emphasis being given to
the training of all personnel involved in the plant's maintenance activities.
Noteworthy are the training ' laboratories which were found to be well equipped
p with mockup equipment and instruments. Some attention is being given to two
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activities which enhance plant performance, Probability Risk Assessment (PRA)
. program and maintenance trending. However, the management goals for PRA have
not been established and maintenance trending is of limited scope.
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The-licensee has established systems to communicate between maintenance personnel
and other site organizations, including quality control, engineering and
operations. Good communication was observed in maintenance, modifications and
outage related activities. In addition, the daily interdepartmental meetings
were noted to be effective and productive and the organization and procedures
for engineering support appear to be working satisfactorily. However, a
formalization of interaction between performance engineers and systems engineers-
and a better uein,4;a of responsibilities, particularly in the failure
determination area, would be beneficial. '
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Radiological controls to reduce exposure have been effectively integrated into
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the JAF maintenance process. The program to ensure that modifications and
routine maintenance work receive an ALARA review is in place and workers were
observed to display good ALARA practices in the field.
III. MAINTENANCE IMPLEMENTATION
The licensee has developed an effective maintenance program which is efficiently
implemented and adequately controlled. Based upon the quality of work observed,
the experience level of the maintenance personnel is considered to be high. '
The mechanical maintenance staff was found to be knowledgeable and well trained
on all aspects of work performed, as were the electrical and I&C maintenance
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groups. The-procedures for performing preventive and corrective maintenance
were considered to adequately support the individual programs. However, some
improvements could be achieved.by a better integration of the efforts of the
I&C and the electrical and mechanical maintenance departments.
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The use of a work control center was found to be a good method for coordinating-
the activities of. the various departme ts involved and for authorizing work and-
tests. The method used by the licensee for documenting maintenance activities ,
and for maintaining equipment history and records appears to work well. However, t
the computer data base was not easily able to retrieve some records. In addition,
documentation of work control packages, post work reviews, and the program for
providing feedback to the various groups should be strengthened.
-The planning of scheduled and unscheduled work is generally wel'1 controlled
with knowledgeable planners directing the effort. Scheduling of preventive,
s corrective and predictive maintenance was determined to be adequate and
completed within the program guidelines. Adequate resources are allocated to.
manage and limit the work backlog.
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The program elements for developing, approving and controlling maintenance
procedures were well documented. However, more attention should be placed in
ensuring consistency of format of the procedures.
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Although the operations department's personnel responsible for post maintenance
testing-(PMT) are considered to be knowledgeable and experienced, the lack of
system engineer's input into the PMT determination and the use of generic in
lieu of more specific procedures are considered to be weaknesses in the PMT
program. The underlying concern is that PMT operational requirements may not
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be recognized, particularly during periods of extensive maintenance activities.
The plant layout and personnel placement of the maintenance facilities were
determined to permit ef ficient operation of maintenance activities. Administra-
tive policies and procedures adequately control the specification, procurement
and receipt' inspection of maintenance related materials and equipment. Adequate
procedures also exist for the storage, tracking, accountability and issue of
safety related materials by-the warehouse. However, it was determined that a
large quantity of materials, including safety related components, after receipt
inspections, are turned over to the various maintenance groups, for unspecified
use. For uhese materials no specific procedures exist for their storage and
for tracking and controlling their use. This is a concern which requires
management attention. Identification , storage and issue of maintenance tools
and instruments were appropriately controlled.
Personnel performing calibrations were properly trained, and calibration
standards were ascertained to be traceable to the National Bureau of Standards.
Review of the licensee's personnel controls indicated that the maintenance
supervisory personnel receive periodic performance appraisals and that the
performance of bargaining unit personnel is informally assessed, on a continuous
basis, by supervisory personnel. Promotions are usually made.from within the
company with supervisory personnel advancing through various levels in the
department.
The testing and qualification of maintenance personnel were found to'be adequate,
as were the licensee's training and apprentice programs which are approved both
by INPO and the State of New York.
One non cited violation was identified with regard to the scheduling of EQ
related maintenance in the I&C area.
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Appendix 2 contains a summary of identified weaknesses.
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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 Policy Statement, dated March i
23, 1988, that states, "It is the objective of the Commission that all
components, systems, and structures of nuclear power plants be maintained
so that plant equipment will perform its intended function when required.
To accomplish this objective, each licensee should develop and implement a
maintenance program which provides for the periodic evaluation, and prompt
repair of plant components, systems, and structures to ensure their
availability".
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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 guidanta provided in
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NRC Temporary Instruction 2515/97 and the NRC Maintenance Inspection
Guidance. The v.mporary instruction includes a " Maintenance Inspection
Tree" that identifies for inspection the major elements associated with
effective plant maintenance.
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l -Scope of Inspection
Site specific-information concerning the maintenance program was provided by
the licensee in. response to the letter' dated February 23, 1990. The team reviewed
.the information submitted by the licensee and planned for the inspection starting
, on April. 16,:1990. The team conducted the onsite. inspection at the FitzPatrick
. Plant from April'30 - May 11, 1990.
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 May 10 1990, an extended
meeting was held with responsible members of the licensee's organization. The
purpose of this meeting was to communicate the strengths, weaknesses, and
unresolved items identified by the team and to discuss the team's preliminary
findings. ' A summary of the inspection team's findings, including a presentation
of an evaluated maintenance inspection tree, was discussed with licensee
representatives including management, supervisors and engineers at the exit
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meeting on May 11,1990 (see Appendix 1 for attendees).
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The Maintenance Inspection Tree
The inspection team's conclusions about the status of the plant's
maintenance program 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 lef t portion of each block indicates how well the topic of
the block is described and documented in the plant maintenance program,
including the adequacy of procedures. The lower right portion of each
block indicates the team's conclusion as to the 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 e marginal
but acceptable condition and red indicates the topic is missing or the
intent of that portion of the tree is not being met by maintenance
activities. Blue indicates the item was not evalv:rrJ or could not be
properly evaluated due to recent changes.
Inspection Findings -
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The inspection team's findings and conclusions regarding the FitzPatrick
Nuclear power Plant site maintenance program and its implementation are
documented in each section of the report. The weaknesses are listed in
Appendix 2.
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I. OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE
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1 .0- DIRECT MEASURES '
Scope
The scopt of this part of the inspection was to review the_ availability,
operability, and the material condition of the plant as it relates to the
implementation of an effective maintenance program.
Conclusions'
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Overall, the condition of the plant, as observed during this maintenance
inspection, was found to be satisfactory. In general housekeeping was considered
good with all areas receiving adequate attention. Various conditions which
should be improved were, nonetheless, found. One such condition is the identifi-
cation of equipment and plant areas. Equipment tags were small or hard to find;-
sometimes no tags could be found. Similarly, elevations and column locations
were almost nonexistent.
The~ only item of potential safety significance identified by the team is the
hanging of instrument calibration pots on cages around instrument racks
without seismic analysis. The pots were removed prior to completion of-
inspection.
1.1 Historic Data
From initial operation until the start of the current outage, the plant has
performed with high availability factors and minimal shutdowns resulting from "
inadequate maintenance. Fuel integrity has remained high with resulting low
radiation contamination and health physics problems.
Based upon historic information, it may be concluded that maintenance was -;
effectively implemented during the first 15' years of operation.
11 . 2 Plant Walkdown Inspection
Scope i
The inspectors performed general plant, as well as selected system and component-
walk down to assess the general condition of the plant, including housekeeping.
Walkdowns included an evaluation of the buildings, components, and systems for
proper identification and tagging, accessibility, scaffolding, radiological
controls, and any unusual conditions. Unusual conditions included but were not-
limited to: water, oil, or other liquids on the floor or equipment; indications
of leakage through ceiling, walls or floors; loose insulation; corrosion;
unreasonable equipment vibration; excessive noise; unusual temperature; and
abnormal ventilation and lighting. Each time a team member was in the plant,
observations were made of these items and conditions.
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. Findings
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In general, the plant appeared to be in good cc ditions and housekeeping appeared
to be adequate for a plant during an outage. However, the machine shop was
. observed to have trash and metal chips on the floor and tools and equipment
left.on work benches. Scaffolding in some areas did not have planking tied
down or' tags hung as required by P'. ant Standing Order PSC No. 51, " Erection of ,
Scaffolds Near Safety Related Equipment", Revision 4. A sheet of 1/16" asbestos-
gasket was found in the hall outside the north door of the maintenance office.
Further investigation into plant procedures revealed the licensee had no program i
in place for bagging / isolating or special handling of asbestos sheet gasket
material. The emergency diesel generator rooms were inspected and found to be
.in very good material condition.
One condition which requires management attention is the identification of
equipment rooms which was considered to be poor. Support columns did not have
plant location markings, and floor elevations were not marked. Also, equipment
and pipe systems exhibited token markings. This was considered to be a weakness
in the plant labelling program. The inspector also noted that PS0-60, Plant
Label Program procedure, was recently developed. The procedure describes a
program for labelling of system valves, major equipment, electrical distribution,
instrumentation, and plant areas. Labelling is scheduled for completion by the
end of 1992.
Equipment out of service was tagged. The tags referenced the correct equipment
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and were filled out consistent with' established plant procedures.
Deficiency tags were attached to equipment needing corrective maintenance. Two
deficiency tags were observed to be several months old (Ref: (1) WRED 71-68366,
AC UPS Generator Breaker Pilot Light (will not light), dated September 28, 1989
and (2) WRED 10-69419, Liquid Sample Valve 10COV204 on RHR Pump B, (no closed
indication), dated June 21,1989). The inspector determined that in both cases
there had been a deliberate decision to postpone the corrective maintenance
until the refueling outage. The deficiencies were verified to pose no significant
risk to plant safety.
Generally, the condition of equipment and materials was considered satisfactory
to maintain operability of components at a level commensurate with the components'
function.
Motor control centers and electrical cabinets were found to be adequately clean.
Condu;ts penetrating fire barrier walls and floors were observed to have fire
stops in place. Some unused wires were observed in the Power Transformer No. 4
control junction box JB-NSS4 which were not tagged and not terminated on junction
blocks. These were verified to be spare wires that were shown as spare wires
on plant drawings. There is no requirement to label individual spare wires at
JAF.
Some dry boric acid crystals were observed at the base of one of the boric acid
injection pumps indicating that there had previously been some leakage at this
pump. This condition was called to the attention of plant personnel.
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On the north end of the main steam tunnel, a main steam branch line 1" SDD-902-3C
was found to be bent. This bend was not shown in plant drawings FP-27C Revision 10
and 11825-6.25-18A. An Adverse Quality Condition Report (AQCR)90-090 was
subsequently written to remove insulation and investigate the bend.
During a review of the general condition of safety related instrumentation
within the reactor building, the inspector observed that instrument calibration
water pots, weighing approximately 15 pounds, had been mounted on the grating
of several rack enclosures. The . inspector also noted that some washers were
slightly larger than the grating holes and that the grating itself was rather
flimsy. In'one case ty-raps had been used for restraining the instrument.
Because damage could occur to safety related inttruments if the calibration
pots separated from their supports, during a seismic event, the inspector asked
the licensee if calculations existed which showed the ..ceptability of the
restraints used. By the end of the inspection, the licensee could neither
justify the installation nor satisfy the recommendations of Housekeeping and
Cleanliness Control Procedure WACP 10.1.7, Exhibit 9.2,5, dated March 1, 1990,
which requires the use of a " chain or wire of 1/4" size or larger." Therefore,
they removed the calibration pots and agreed to perform an engineering evaluation
prior to permanently reinstalling them.
Reactor water cleanup return line isolation valve 12MOV69 was observed to be
installed without T-drains. However, prior to the end of the inspection, the
licensee provided documentatton which showed that no T-drains were required-
for that specific application.
A walkdown was made to assess the plant's compliance to fire protection
requirements, All lumber located in the work areas was properly treated and
considered to be flame retardant. Accumulation of combustibles was kept to a
minimum with maintenance workers periodically collecting trash from their job.
Wherever welding was performed, a flame retardant material-made of fiberglass
was used to-surround the activity and control sparks. Fire extinguishers were
also on hand, in case they were needed. All fire extinguishers inspected had
been properly certified in accordance with plant procedures.
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11. MANAGEMENT SUPPORT OF MAINTENANCE
Scope
The scope of this part of the inspection was to determine through appropriate
examinations the degree of management support of the maintenance process.
Included in these examinations were the application of industry initiatives,
and participation of management in the maintenance process.
2.0 MANAGEMENT CNMITMENT AND INVOLVEMENT
SJL0 ele
The scope of this section is to determine management involvement in supporting
and using industry initiatives, and providing leadership in maintenance training,
self evaluation and use of historical plant data.
Conclusions
Licensee management has initiated several significant programs to optimize the
performance of plant maintenance. These include the 1984 planned maintenance
program, self assessments of maintenance, the corporate nuclear maintenance
program manual, an extensive training and qualification program, interaction
with nuclear industry groups and other nuclear utilities, the development of
systems engineering cap:bility and the formation of specialized task groups
including the planned maintenance task force (PMTF). On the basis of these
management initiatives, it is concluded that management has had a high level
of commitment to and involvement in the maintenance process.
2.1 Ayp11 cation ai industry Initiatives
The licensee is a participant in various nuclear industry groups that provide
a forum for interchange of plant maintenance experiences with other nuclear
utilities. Th3se industry groups include INPO, EPRI and NUMARC. The plant
uses the NPRDS data system for reporting and tracking plant problem components
and participates in the INPO nuclear network system.
The plant has a systems engineering program with assignments and responsibilities
defined in procedure PS0-1. The system engineer is the focal point for
information collection and assessment in regard to system design, operations
and maintenance.
On the basis of licensee involvement with industry groups, and its use of
information obtained through both formal and informal contacts with industry
committee memoers and those at similar nuclear plants, the maintenance
inspection team found that tut licensee has aggressively applied useful
industry initiatives.
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2.2 Management Vigor and Example
Licensee management has demonstrated their interest in plant maintenance and
operations by several initiatives. These include issuance of the implementation
plan for the planned maintenance program by memorandum, dated November 9, 1984.
This maintenance plan included many of the attributes included in the NRC
maintenance inspection tree that are essential to a properly functioning
maintenance program. Progress in implementing the planned maintenance program
was monitored by various means including the conduct of a series of self assess-
ments, each of which identified actions aimed at improving plant maintenance.
The Corporate Nuclear Maintenance Program Manual, issued in February 1990, presents
the corporate policy on the nuclear plant maintenance program. This policy
manual states the background, policy, requirements, responsibilities, authority,
references and documentation needs for the primary areas of maintenance.
3.0 MANAGEMENT ORGANIZATION AND ADMINISTRATION (CORPORATE AND PLANT)
Scope
The objective of this section was to assess the effectiveness of the organization
and administration of the maintenance functions and the maintenance program.
The specific areas inspected to provide a broader perspective of maintenance
activities included: the existence, availability and scope of a formal mainten-
ante program; maintenance policy, goals and objectives; allocation of resources;
identification and definition of maintenance requirements; maisetenance
performance measurements, the documentation control system for maintenance;
and the maintenance decision process.
The maintenance program at JAF is based on a plan that was developed in 1984
(Ref: Memorandum, W. Fernandez to Distribution, J0PS-84-133 dated
Neve.tbcr 9, 1994;. Written administretion pnlicies and guidelines identify the
responsibilities for maintenance including the development of work level
procedures and schedules. Work level procedures have been developed that
control most scheduled and routine maintenance activities.
Many of the current work level procedures are of recent origin or have undergone
recent revision. This reflects the evolutionary process that has beer. followed
at JAF to improve the maintenance program. It also indicates that the maintenance
program is not fully mature.
3.1 Program Coverage for Maintenance
The maintenance program at JAF is described in a multi-level hierarchy of
documents. The corporate maintenance program is described in NUAP-5.10 and in
the Corporate Maintenance Program Manual (CMPM). Responsibilities for
administration, review and updating the program are described in administration
docume,,ts AP-1.1, 1.4 and 3.1. The program is further supported by Work
Activity Control Procedures (WACPs), Quality Assurance Procedures (QAPs), Plant
Standing Orders (PS0s), Maintenance Department Standing Orders (MD50s),
Instrumentation and Control Department Standing Orders (ICS0s), Operating
Department Standing Orders (OD50s), Technical Service Department Standing Orders
(TSS0s) and a group of radiation control documents.
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Special training is necessary to make plant personnel knowledgeable in the ,
complex system for conducting work and of the relevant documents and procedures.
Coordination at the working level is the responsibility of the Work Control 7
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Center (WCC). The inspector determined through interviews and observation that
individual workers had a good working knowledge of the procedures and documenta-
tion for conducting work tasks.
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3.2 Establish Policy, Goals, and Objectives
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Management goals and performance indicators are published in PS0-36. -This [
document is updated annually. Goals and commitments are tracked according to
PSO-35 and PSO-58. The inspector determined by interview of plant personnel
that supervisory personnel were aware of administrative policy, goals and.
objectives.
Weekly planning meetings are conducted by the WCC at the worker level. These
meetings are used to resolve conflicts and verify or assign priorities to work :
tasks. The inspector observed that maintenance worker; utilized approved ;
procedures for most tasks. Occasional deficiencies or ambigaities in the 3
procedures were observed. In these cases, the worker tended to make -
discretionary interpretations of the procedures. However, workers are trained
not to proceed on any work not specified in a work request.
3.3 Resource Allocation
Direct observation of maintenance activities, review of completed maintenance
actions,_and a review of selected performance indicators show that JAF management
has allocated sufficient resources to maintenance activities. Personnel are
generally available in sufficient number with satisfactory training and
qualifications.
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During normal- plant operation, essentially all maintenance personnel are full
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time employees. During refueling outage, the number of employees is approximately
l doubled by use of contract and temporary personnel and the standard work hours
are extended to 6 ten-hour days per week. Night shifts are added on an as-needed '
basis. Turn-over of permanent plant personnel has been low. Shop and tool *
areas are adequate. A new warehouse is under construction to provide better
parts control and'to alleviate some crowding in the administration and turbine
buildings.
3.4 Maintenance Requirements (Corporate and Plant)
The maintenance program at JAF includes surveillance, preventative and corrective
maintenance. The surveillance and preventative maintenance includes some of
the attributes of predictive maintenance.
Scme specific predictive maintenance activities are being routinely conducted
on pi e components. These include chemical analysis of oil samples from
selected electrical and mechanical equipment. 011 sample points are being
installed on some equipment to facilitate the sampling process. Vibration data
are being collected from some mechanical components and thrust, current and time
' data are being collected from motor operated valves.
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Baseline data have been collected and stored in computer data bases to permit '
trend analyses as data are accumulated. This program is formalized for some
plant components, but is presently limited by incomplete baseline data and data
base computer programs.
The Plant Maintenance Task Force (PMTF) was formed to provide continuing review .
and improvement in the plant maintenance program. The responsibilities of the
PMTF are described in plant maintenance document PM-01. It mandates an ongoing
program for implementing regulatory requirements, defining component maintenance
tasks and frequency and review of component maintenance history. The procedures
for implementing this program are described in plant documents PMTF-3, 5 and 6.
The inspector determi%d that there are 4 levels of priority for corrective ,
maintenance work:
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1. Emergency - Requires immediate action.
2. Priority 1 - To be corrected within 1 week.
3. Priority 2 - To be corrected within 1 month.
4 Priority 3 - To be corrected when convenient. -
All plant personnel are encouraged to initiate corrective maintenance actions ,
by either filling out a maintenance request form (MR) and attaching appropriate ,
deficiency tags to the relevant components or by informing plant supervision of
a problem. The MR is then evaluated by the responsible group supervisor to
determine if action-is required. If action is required, a work request is
processed in accordance with established procedures.
3.5 Performance Measurement
T'e licensee conducts performance measurements in accordance with Performance
Engineering Procedure PEP 2.1.2, " Weekly Unit Performance $1onitoring",
Revision 0, dated Noved er W 9. This procedure addressr:$ a standardized method
for collecting, storing, analyzing, and reporting the data monitored, and
provides a means of early detection of degradation in the monitored system
parameters and equipment performance. Data acquisition is obtained from the
licensee's Emergency Plant Information Computer (EPIC) system printouts and
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logs. Adverse conditions having a significant effect on the ef ficiency or '
availability of the plant are brought to the attention of the performance
engineering supervisor through this system.
The information is entered by the performance engineering group into various
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computer programs which analyze the data, calculate correction factors and
variables and produce performance spreadsheets and graphic plots of the data.
The spreadsheets and graphs are examined for trends or v.11ues that affect plant *
performances, reliability or efficiency. Although the scope of monitoring is
limited, the licensee is making progress in this area, as evident by the reports
reviewed.
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In addition to the above, the licensee has instituted PSO No. 58, " Management
Observer Program", Revision 2, dated February 1990, which uses management ,
personnel to observe housekeeping, overall plant performance, and reliability. '
Management observers, as defined by the PSO, are the resident manager and his
staff down to the assistant department heads. Areas of observation are, to ;
some extent, limited by the PSO, in that each observer will only observe tasks ,
in two of the eight departments identified in the PSO. Observations are
conducted on a designated time frame and, upon completion of the observation,
they are submitted through a Management Task Observation Report to the
Superintendent of Power. When reviewing the report file, the maintenance team ,
' inspector observed a number of missing reports from the last quarter of 1989. .
The licensee had previously. identified this concern in January of 1990; however, '
no corrective actions were taken. The file was not well maintained.. ;
3.6 Document Control System '
Th9 inspectors evaluated various procedures in place at JAF to ensure that
proper document control included establishment of accountability, authority,
documentation requirements, and responsibility. The inspectors also reviewed
the plant procedures to ensure that updating and traceability of plant i
documentation was addressed. A partial list of related procedures includes:
Administrative Procedure API.2, " Plant Operating and Review Committee" which
directs the periodic review of plant procedures; API.4, " Control of Plant
Procedures", which establishes requirements for initiation, review, approval,
revision, temporary changes, withdrawal, and control of plant procedures; AP3.1,
" Procedure for Maintenance Procedures", establishes a format for the procedures
and relative characteristics; Maintenance Department Standing Order, MD-50-16,
"Mair.tenance Work Planning and Routing of Work Requests", which establishes
controls for pre-job planning; Plant Standing Order, PS0 41, " Operation of
Archival Storage Facility", which establishes guidelines for operation of the
licensee's archiving process and storing of plant documents; PS0 46, " Procedure
for Control of Vendors Manuals", which establishes control and Ostribution of +
technical vendor manuals throughout the facility; and Work Activity Control
Procedure, WACP 10.1.1, " Procedure for Controls of Maintenance and Engineering :
'
Assistance Requests", which describes program for reporting plant system material
deficiencies, for performance of corrective maintenance anc repair of equipment,
for controlling performance of equipment modifications, for initiating request
for work ' permits, and for initiating requests for engineering assistance or
plant modifications.
The majority of the documents reviewed for this element have been established
for some time and are being implemented.
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3.7 Maintenance Decision Process
The inspectors reviewed the Corporate Nuclear Maintenance Program Manual,
various plant procedures, and engineering documents to determine the extent to
which JAF's management is directly involved with decisions regarding maintenance
activities. The inspectors concluded that the program for equipment upgrade,
for replacement of plant components and for evaluating effects of plant aging
could be strengthened. In the past, the licensee's management did not give
high priority to plant aging considerations, but they are aware of ongoing
discussions on this subject. Decisions for upgrading and replacing plant
equipment, in the past, were addressed on a case by case basis, depending on
necessity and system parameters. Corporate engineers as well as site system
engineers and equipment specialists take part in assessing the need for action.
Although the licensee's final maintenance goals are being achieved with good
results, the inspectors concluded that, due to the lack of guidance documentation,
the consistency of future program implementation could be at risk.
4.0 TECHNICAL SUPPORT
The inspector assessed the area of technical support by evaluating the extent
to which engineering principles have been factored into the maintenance process.
This was accomplished by evaluating the performance of the various engineering
organizations, studying plant procedures, sampling work packages, and observing
maintenance activities. Other organizations whose performance was evaluated
included Quality Control, Safety, and the Planned Maintenance Task Force (PMTF).
4.1 Engineering Comtaunication Channels
The inspector evaluated channels of communication throughout the course of the
entire inspection noting situations that required communication and evaluating
performance in this area.
The primary written method of communication between the plant organizations and
engineering is accomplished through a request for engineering assistance by
plant procedure WACP10.1.1. This procedure states that engineering assistance
can be requested "to perform evaluations, desire for mods, etc.", subjecting
the use of this procedure to wide interpretation by plant personnel. Therefore,
virtually any plant situation requiring engineering review compels the use of
WACP 10.1.1. Other instances which require maintenance personnel to communicate
with engineering are contained it. specific maintenance procedures. Certain
situations in these procedures specify that maintenance personnel are to consult
with the cognizant engineer, if unusual conditions exist. Engineers are also
kept apprised of maintenance concerns through their participation in the
maintenance daily planning meetings,
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The inspector found evidence of other forms of communication being carried out
between the various engineering organizations which are not covered by plant
procedures. The use of performance memoranda by performance engineers, to
convey adverse system / component failure trends to system engineers, is one
example. A similar situation was also noticed with the PMTF organization and
the system engineering group.
Conclusion
Formal and informal communication between the engineering organizations and the
maintenance department are effectively being accomplished. Engineering
participation in maintenance activities and mutual respect between these
organizations were both evident. However, some plant documentation covering
several key situations which require communication does not exist. Communication
at the plant would be enhanced by formalizing the interaction between the per-
formance engineers /PMTF and the system engineers. The licensee recognizes
this problem and has committed to formalize these lines of communication.
4.2 Engineering _ Support
The inspector examined the area of engineering support by evaluating the program
established for performing failure determination and analysis, assessing the
use of NPRDS data for identification of potential problems with systems / components,
and evaluating the effectiveness of the system engineering program.
Engineering responsibility for failure analysis is contained under the Technical
Services organization and within the maintenance organization. Both groups are
responsible for performing the analysis. However, the criteria for when either
group is responsible for performing it are vague. For example, MD-S0-16 requires
maintenance engineers to perform failure analysis of all Category 1 and M
components not already subject to engineering reviews, but the procedure doesn't
specify which type of failures are subject to engineering reviews by other
organizations. Involvement of system engineers was noted whan a system / component
failure was safety-related or involved a modification. Thit observation was
based on conversations with system / maintenance erpineers and not apparent in
plant procedures.
Failure analysis is also being performed by the Performance Engineering
organization for use in NPRDS. Performance engineers review all plant work
requests to search for failure data reportable to the NPRDS. If adverse trends
are noticed through excessive failures, a performance memorandum is written to
inform the system engineer. In addition, the Component Failure Analysis Report
(CFAR) compares plant component failure rates to industry averages. The
inspector determined that NPRDS data, including the CFAR, were being appropriately
used by system engineers. However, plant documentation related to CFAR's was not
in place.
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The effectiveness of the system engineering program was evaluated by the f
inspector. The general support for this program by management and other '
organizations was favorable. The system engineers are adequately involved in i
plant activities including: performing evaluations in conjunction with i
unusual occurrences; active participation in tests conducted for evaluating -
system performance; and appropriate review of outside operating experience. l
Initiatives have also been taken by the System Engineering Supervisor to improve ,
the effectiveness of the program such as documenting prioritized goals for the- >
program, and developing system reference books. Some inadequacies, however, '
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were identified in the. System Engineering Program procedure, PS0-1. Most notable i
was a requirement for trending of system parameters. This was not being performed
by the system engineering program, nor was there evidence of developed plans to
do so. Other prob 1 cms included reference to the use of the PRA which doesn't
exist, and lack of guidance on when to use the System Engineering Memorandum.
The licensee recognized these procedural problems and is in the process of .
modifying PSO-1. i
Conclusions
The overall level of support from the engineering organizations to the maintenance
process was determined to be good with certain noted exceptions. Clarification
is needed in delineating responsibilities for failure determination and analysis.
Integration of plant procedures related to this area would be beneficial, A >
program to perform analysis of adverse failure data identified in the CFAR is
not documented. It was recognized that many of these programs are new and 4
that the licensee was evaluating the best method for conducting business prior
to documentation. The licensee is committed to correcting these problems through +
modifications to the plant procedures.
4.3 . Role of PRA in the Maintenance Process ,
The purpose of this section of the inspection was to determine the extent to #
which the Probabilistic Risk Analysis (PRA) or the risk. concept is ccnsidered ,
in all aspects of the maintenance process. This includes not only planning, ;
scheduling, and prioritization of work, but also engineering evaluations, i
Risk based concepts are presently.not considered in the planning, scheduling,
and prioritization of maintenance activities at JAF, Discussions with the
licensee indicate they plan to have the PRA completed by the end of 1990.
However, there is no evidence of documented goals for the use of the PRA once
it it nmpleted. The fact was also noted in a memorandum from the QA Super--
.intendent, dated August 24, 1989, which notes there _is no program to assure
that the benefits of the PRA can be implemented in a timely manner. Despite .
the lack of a formal PkA and integration of its concepts into the maintenance
process, the inspector found that risk has been considered in various situations.
For instance, the inspector noted the use of fault tree analysis by Technical
Services to examine the need for an emergency diesel generator fuel cutoff valve.
Also, the Planned Maintenance Task Force used risk concepts to rank the importance
of JAF check valves to be inspected during the 1990 refueling outage.
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Conclusions ,
The use of risk assessment concepts was found in a few areas-of the maintenance
process. However, management goals have not been established to consider the ,
use of the PRA. This includes consideration of how it will be used in planning,
scheduling, and prioritization of maintenance activities.
4.4 quality Control in the Maintenance Process
f
The inspector evaluated the presence of Quality Control (QC) in the maintenance
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process. _This was accomplished by looking at the involvement of QC inspectors ;
and reviewing the systems which are in place for reporting and correcting
quality deficiencies. *
QC inspections are essentially established by the maintenance department, when
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a maintenance procedure is initially written. These procedures are reviewed by f
the QC department for verification of proper inspection points. Several
completed work packages were reviewed by the inspector, and it was determined -
that QC inspection points were appropriately assigned and followed. Instructions '
for these inspections are contained within the maintenance procedures themselves,
and they were found to be generally adequate, with a few noted exceptions. In
work request #77288, involving maintenance of a motor operated valve (MP59.41), i
the procedure was unclear in a section requiring a QC inspection point. QC [
corrected-this inadequacy by using a temporary modification to the procedure.
Other cases have occurred due to the fact that many maintenance procedures are ,
new.
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The lack of criteria to aid in the determination of appropriate QC inspection
' hold points was noted by the inspector. At present, the establishment of these
points is based on the discretion of the individual responsible for writing the
maintenance procedure, and subject to appropriate QC review. Plant wide
guidance in this area would ensure consistency of maintenance procedures. The ,
licensee noted this deficiency and plans to correct the problem through che -
development of guidelines for all plant inspections. !
The QA department has an established program in place for the entification, I
documentation, and correction of quality deficiencies. The pro,eam was found
to be very comprehensive, covering deficiencies related to materials, equipment
malfunctions, procedures, and processes. A mechanism was in place for escalating-
Adverse Quality Condition Reports (AQCR's) to high levels of management for
resolution. The inspector found the escalation process was being actively used
with a few exceptions. One example was AQCR 88-017 which was not escalated
, properly and, as a result, has remained unresolved since 1988; this particular
example was determined to be an isolated case of inadequate escalation. i
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The procedure associated with corrective action of AQCR's requires that a root
cause analysis be performed by the responsible department. Guidance for
performing this analysis is not in place, and formal training for root cause
analysis is not available to plant personnel. The licensee has taken steps to
rectify this deficiency through the initiation of a plantwide Corrective Action
program. This program will integrate several plant procedures related to causal
analysis and provide training to employees in the recognition of adverse
conditions and performance of causal analysis.
Conclusions
The QC department is actively involved in maintenance activities and was
considered to be functioning well. It was determined that documented inspection
criteria guidelines would ensure that a consistent approach is taken with regard
to preparation of maintenance procedures. The quality deficiency program is
functioning well, but needs more concise guidance with regard to root cause
analysis.
4.5 Integration of Radiological Controls into the Maintenance Process
Scope
The purpose of the inspection was to determine the extent to which radiological
controls are integrated into the maintenance process. This area was reviewed by
observing ongoing maintenance activities, by reviewing Radiation Protection's
involvement in the planning and preparation for :upporting maintenance work,
-and by reviewing the licensee's program for maintaining exposures as low as
reasonably achievable.
Findings
For the 1990 refueling outage, the licensee set the As Low As Reasonably
Achievable (ALARA) exposure goal at 500 man-rem. This goal included 200 man-rem
for routine operations and 300 man-rem for outage related work. Previous annual
cumulative exposures for refueling outage years were 785 man-rem in 1988 and
940 man-rem in 1987. The licensee anticipated that, with the dose rate reductions
achieved with the recirculation system's decontamination effort, undertaken
during the 1988 out' ige, and with the initiation of the primary system's zinc
injection program, begun in 1989, the dose rates inside the drywell would be
significantly lower than those encountered in previous outages. Based on the
anticipated work a:tivities in 1990 and the historic exposure data, it appeared
that the licensee had set a reasonable 1990 ALARA goal.
As of the end of April 1990, the licensee's exposure reached was 425 man-rem,
which was 210 man-ree over the exposure goal for the period. The licensee stated
that this was primarily due to unanticipated high dose rates inside the drywell
end to the additional numuar of weld overlays required to be completed during to
current outage.
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At the beginning of the current outage, radiation surveys indicated that the
dose rates inside the drywell were significantly higher.than anticipated.
Therefore, during the inspection, the licensee's management met with the vendor
for the zine injection program to evaluate the effectiveness of the program in
reducing the source term. The licensee has decided to continue, at least for
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the immediate future, with the zine injection program. Meanwhile, the licensee :
is evaluating the possibility of another recirculation system's decontamination
effort during the next refueling outage.
In addition to the zine injection program . sed the recirculation system
decontomination, the licensee has in place other programs to reduce the source '
term at the facility. These include a cobalt reduction program and a hot spot
identification and abatement program. As part of the cobalt reduction program,
the licensee has replaced several control rod blades with cobalt free control
rod blades. Although the source term at the facility remains relatively high,
management appeared to be committed to reducing it and their involvement in ,
this matter was considered good.
The licensee has established criteria for determining which maintenance tasks
require an ALARA review. These criteria require an increase in the level of
ALARA review for maintenance activities involving higher man-rem exposures and
a follow-up review for those tasks that significantly exceed the ALARA estimate. ,
The team reviewed several ALARA reviews for radiologically significant maintenance '
work and found them to contain appropriate ALARA requirements such as increased
mock up training to reduce the individual's time in radiation areas and ensuring
that adequate shielding is in place. In general, the licensee's program to
ensure that outage maintenance work inside the radiologically controlled area 1
receives an ALARA review is adequate.
The tearr reviewed the licensee's mock up facilities. Mock up equipment includes
a rtcirculation pump seal cavity, control rod drives, weld overlay equipment,
hydraulic control units, as well as various valves and electrical breakers. The
licensee has also initiated the use of new valve actuation testing equipment i
which reduces the amount of time individuals must stay in radiation areas while
. conducting valve actuation tests, The vendor for the new equipment spent one
week onsite training licensee personnel on the proper use of the equipment.
Discussions with training supervisors, ALARA personnel, and maintenance workers
indicated that the licensee was making effective use of the mock up equipment
to minimize personnel exposures.
The team also noted that ALARA training is provided to workers in the General-
Employee Training. By direct observation and discussions with workers, the team
determined that workers are aware of the need to minimize exposures and do take
ALARA precautions while conducting work.
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The team conducted several tours to assess the upkeep of the facility, including
housekeeping. In general, the housekeeping and material condition of the reactor
building appeared to be adequate. The team observed several areas of the turbine
building where improvement could be made in the general housekeeping and several
instances where used oily rags and protective clothing, including coveralls,
booties, cotton liners, and gloves, were left on top of equipment or on the
floor and not placed in containers, as required. The team also noted a mop,
labelled as contaminated, and oil from equipment, also labelled as internally
contaminated, which were left uncontained on the floor.
The team observed maintenance activities and reviewed Radiation Work Permits
(RWP) for work inside the drywell. The radiological coverage for maintenance
activities inside the drywell was generally good. The team reviewed several
RWPs for maintenance work in the reactor building and turbine building. The
team noted that several of the RWPs for High Radiation Area entries did not
require that the individuals making the entry be provided with a radiation
survey instrument, an alarming dosimeter, or be accompanied by an individual
qualified in radiation protection procedures and radiation survey instruments.
In addition, the RWP did not specify the frequency at which periodic radiation
surveillance was to be conducted. This matter is discussed in the report for
NRC Inspection No. 50-333/90-17 which was being conducted at the same time as
the Maintenance Team Inspection.
Conclusions
The licensee has implemented an adequate program to ensure that modification
and routine work inside the radiologically controlled area receive an ALARA
review to reduce cumulative annual personnel exposures. The licensee also has
made effective use of mock up facilities for training personnel; workers
demonstrated good ALARA practices in the field. Improvements need to be made in
the general housekeeping of the turbine building. Overall, the integration of
radiation protection into the maintenance process is considered good.
4.6 Safety Review of Maintenance Activities
This portion of the inspection focused on the consideration given to safety in
the performance of maintenance work. Safety at JAF is integrated into the
maintenance process in a number of ways.
The safety program at JAF has under gone recent improvements as a result of an
increasing number of work related injuries. The new program was implemented in
January,1990 and includes a list of initiatives primarily aimed at increased
Safety Supervisor responsibility. These initiatives include more participation
in Maintenance Department daily planning meetings, and a more proactive safety
violation program. The safety program has also attracted more management
involvement, and the inspector observed participation in safety meetings by the
Superintendent of Power. This new program, however, has not been integrated
into the plant procedures. Though no firm commitments were made, the licensee
indicated that this effort would be undertaken sometime in 1990. 1
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During routine walkdowns, one team memoer. noted the presence of uncovered :
asbestos containing gasket material outside the mechanical maintenance area.
Though asbestos handling procedures are ir. place, they are not informative of
this type-of plant situation. The licensee is presently reevaluating procedures ,
to determine proper storage and handling requirements for this type of material.
Conclusions .
The site safety _ program was only recently est0blished at JAF, and has generated. ,
renewed attention from management and plant workers through the effective use
of safety violations. Although too early to assess the impact to the number of '
work related injuries, there is evidence that the overall awareness of safety
has recently improved. In order to make this program more visible, plant -
procedures should be modified. In partic.ular, the plant procedure for the I
-storage and handling of asbestos 3hould be reevaluated to consider all possible :
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plant situations.
4.7 _ Regulatory Documents
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The system in place to ensure that regulatory documents are factoried into the
maintenance _ process was examined. The inspector observed that management
controls are in place for controlling regulatory document.t. These controls ,
. include the establishment of_ focal points to ensure that changes to these
documents are properly administered. - Assistance is also gi/en in this area by
-system engineers, who are responsible for ensuring consistency of system ,
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operating characteristics in documents such as technical. specifications and the
FSAR, The licensee has also established a computer tracking system, known as '
the Action Commitment Tracking System (ACTS), to track documents such as NRC
commitments.
The Planned Maintenance Task Force (PMTF) has a program in place to ensure that
regulatory documents are factored into the preventive maintenance program.
This. requirement is established through procedure PMTF-03. Accordingly, the
PMTF is required to search designated regulatory documents for applicability
prior to establishing equipment preventive maintenance. frequency.
Conclusions ,
The licensee has established adequate measures to ensure that changes to
regulatory documents are factored into the maintenance process. Both, plant
and corporate m agement have been helpful in giving regulatory documents the
proper attenti a.
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III. 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 l
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 the effectiveness
of these controls through observations of work in progress; through a review of
completed work orders, procedures, and other documentation associated with
maintenance, training of maintenance personnel, tools in stock, and spare parts;
and through discussions held with all levels of personnel.
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Scope
The purpose of this part of the inspection was to determine .ae effectiveness- '
of maintenance work controls, and the quality of work performed. The controls
established in the following areas were evaluated in determining the effective-
ness of the maintenance program: review of maintenance in progress, work order
control, equipment-records and history, job planning, work priorities, work
scheduling, backlog controls, maintenance procedures, port maintenance testing,
and review of completed work documents. The evaluation of the above sections
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of the maintenance work control program included such areas as observation of l
maintenance in progress, review of completed M'/Rs, inspection of selected systems
and components and discussions with perse:inel.
Conclusions
The licensee.has tatablished an effective maintenance program which is
effectively implemented. Most work is of high quality and adequately controlled.
5,1 Maintenance in Progress
The review of maintenance in progress was evaluated by considering work
performance in accordance with procedures and station policies, goals and
objectives. *
5.1,1 Mechanical' Maintenance in Progress .
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The inspector observed work in. progress in conjunction with snubber functional'
testing, snubber removal and replacement, and snubber overhaul / repair. Additional
work observed included the check valve In-Service Testing (IST) Program, repacking ,
of "B" condensate pump, replacement of main feed check valve 34NRV-111A, and.
repairing of various motor operated valves, including service water and emergency
service water system valves.
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Positive interactions between maintenance personnel and various engineering '
groups was evident during the inspectors observation of check valve In-Service
Testing-(IST). Furthermore, maintenance personnel were observed assembling ,
various service water system check valves while the Quality Lontrol Department
was video taping the valve internals and adjacent piping utilizing state-of-the-art
fiber optic equipment. Additionally, the engineering technical staff was on-hand
to evaluate and to determine appropriate actions, as necessary. Procedures
were followed and steps were properly initialed and dated. QC personnel were 3
on-hand and available from job initiation to completion. The team work and ,
synergism observed during this maintenance activity was considered a strength. '
The snubber functional test program was observed to proceed well, despite the
number of functional tests- failures (5 hydraulic and 2 mechanical) recorded.
As a result, more than 160 snubbers were functionally tested or planned to be ,
functionally tested during this outage.
Three teams of qualified personnel performed within the frame work of this i
program: (1) Snubber test stand operator and QC technician; (2) Snubber repair
bench mechanic and QC technician; and (3) Snubber removel/ installation mechanical '
personnel and QC technicians. ,
After a snubber has passed the functional test, a QC accept tag is attached, i
and is made available to replace a designated snubber of the same size in the ;
plant. QC ensures'that the specific plant location and the unique snubber *
. identifier number is recorded. Metal identification tags are also installed on
the snubber. If a snubber fails its functional test or an abnormal condition ,
exists, it is inspected and repaired. Newly tested and installed snubbers are
painted orange to aid in location identification. The. snubber program engineer i
is responsible for the selection of snubbers which need functionally testing, ~
as per Technical Specifications Section 3.6.1/4.6.I. The observation of the
overall implementation and operation of this program by the inspector was -
considered to be a strength.
The-inspector also observed maintenance work in progress concerning (1) The B
Emergency diesel generator (EDG) power assembly maintenance and preventive-
maintenance, (2) standby liquid control pump A discharge surge accumulator ,
repair, (3) installation of residual heat removal (RHR) and core spray (CS) .
pump motors.
Generally, the mechanics were knowledgeable, maintenance procedures were adequate.
and being followed, and good worker attitudes were observed. Good communication-
was observed between maintenance and quality control personnel. The inspector -
observed good interaction between first line supervisors and their mechanics. '
One problem was identified with the core spray pump maintenance. The inspector
observed that two openings in piping associated with the core spray pump were
not sealed to prevent intrusion of foreign objects; covers were promptly installed
once identified.
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Conclusions
The inspector concluded that mechanical maintenance activities were adequate
and were accomplished by skilled maintenance personnel. The maintenance
personnel appeared knowledgeable and well trained on all aspects of the work
performed. QC involvement was evident throughout the work observed and the >
overall organization of the maintenance activities was considered a strength, ,
5.1.2 Electrical Maintenance in Progress '
Findings $
The inspector observed the following work in progress:
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Preventative maintenance on 600 volt, 23MOV31 Limitorque Motor Starter per
procedure MP 56.1
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Preliminary functional test of RHR isolation Valve 10MOV17 (preliminary
VOTES test)
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Replacement of brushes on UPS Motor Generator per procedure MP 58.2 1
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Baseline test of RCIC Turbine Steam Valve 13MOV131 per procedures MP 59,38 '
and 59,40 (MOVATS test)
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Annual service discharge test of 125 Volt Station Battery 71SB2 per
procedure MP 57,6
The inspector observed that the technicians appeared knowledgeable in the plant -
requirements and of the work being performed. A spot check of the training
records of the participating technicians showed that each had received training
for the task being performed.
With the exception of the functional test of the RHR valve 10MOV17, all work
was conducted according to written procedure. The inspector was told that this
valve had been recently overhauled and that new baseline test data would be
taken according to approved procedures following the preliminary functional
. test being observed,
The inspector noted that preparation for the observed work was adequate, with-
-consideration given to proper approvals, use of calibrated test equipment,
tagging procedures, quality control and safety. The work requests forms
indicated the safety category (1, 2 or 3) of the applicable components. However,
work procedures at JAF are the same for all safety categories. Quality control
and supervisory personnel were observed to be present for most safety category
1 work. Except for the preliminary functional test of the 10MOV17 valve,
appropriate as-found and as-left parameters were recorded. Post maintenance
testing was also included in the procedures when applicable.
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The procedures used in the observed work were all revised just prior to the i
refueling outage. The procedures were found to be sufficiently clear and easy i
to follow by reasonably trained personnel. However, some instances of ambiguity
or deficiencies were observed. For example, in procedure MP 56.1, there is an l
implied requirement (on page 24) that the technician'should verify that the ;
motor starter overload heaters are rated a minimum of 300*4 of full load amps,
for safety-related MOVs and 100's for non-safety-related motor loads. Since the
motors are remote from the motor starter and often inaccessible the technician
does not have any simple method for making this verification.
This concern was submitted to the licensee who responded that the maintenance
procedure would be revised to require that the technician verify overload heater .
ratings, as found in the field, against plant drawings. Current plant drawings
do not include this information but are being revised to include it.
,
Conclusions :
Field observations indicate that maintenance work performed by electrical
personnel at JAF is reasonably well managed and that the written procedures are
generally acceptable. Where procedures are lacking, improvements are being
made and the ingenuity and good training of technicians has been sufficient to
overcome imperfections in the present system.
5.1.3 Instrumentation & Control Maintenance in Progress
Findings
The inspector observed work being performed by several technicians in the
Instrument & Control (I&J) group. The work primarily consisted of instrument
. calibrations which are periodically performed to ensure system performance
within design specifications. The inspector also witnessed work in progress
associated with a High Pressure Core Injection (HPCI) modification and a post
modification test associated with Scram Discharge Instrument Volume. +
While witnessing the above work, the-inspector noted that good maintenance
practices were employed and that quality control check points were employed.
The quality of work observed and discussions with supervisors and technicians
involved indicate that I&C personnel are generally knowledgeable in the plant
, requirements and in the tests being performed. The-inspector also reviewed
l training records of representative technicians and found them to be appropriate
- for the tasks being performed. In all but one case, test' equipment and tools
were adequate and used within the calibration period. The exception observed
involved a current generator requiring weekly calibration and being used to
test the accuracy of some ammeters. In this case, the calibration period had
expired. However, the technician was using a calibrated ammeter in series with
the output which assured the required accuracy.
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Revii., cf work packages of activities being observed revealed that approval
signatures and authorizations had been obtained and that the latest-documentation,
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including vendor manuals, was being used. Tagging of equipment out of service
was adequate as well as housekeeping and cleanliness. Supervisory personnel
were observed to provide adequate oversight and, for safety related work which
i safety and ALARA rules were observed and technicians were noted taking radiativn
exposure readings in the area of the work activities.
Within-the scope of the inspection, only two minor deficiencies were observed.
In one case, where an HGA relay was being calibrated, the procedure followed
pertained to the calibration of a similar relay, type HMA. In addition, the
training module for relay calibration pertained to yet another relay, type
HFA. Discussions with the technician and his supervisor revealed that, though
inappropriate, the procedure did permit its use for HGA relays and that the
latest vendor manual did not specify calibration requirements.
The other case involved the post modification testing of the Scram Discharge
Instrument Volume instrumentation. The test required recording the as-found
calibration of the transmitter and recalibrating the loop according to the
applicable procedure. -It was determined later, a leaky-instrument isolation
valve prevented the technicians from maintaining the system at the required
pressure for a period of time long enough to take accurate readings. As a
result, the recording of as-found readings was not considered to be very
accurate by.the inspector. However, for.the recalibration effort, the
responsible technician, after various unsuccessful attempts to stabilize the
output, decided to stop the test and evaluate the appropriate course of action, j
Conclusions
Field observations of 1&C personnel performing maintenance activities indicated
that good maintenance practices were employed and that technicians were generally
knowledgeable of work assigned to them, However, some minor deficiencies were
observed which could be resolved with more attention to details.
5.2 Work Order Control
Scope
-The. inspector's objective in this area was to evaluate the effectiveness of the
- maintenance work control process to ensure that plant safety, operability and
reliability are maintained, The following areas were evaluated:
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Maintenance in Progress
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-Work order control
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Equipment records history
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Work prioritization and backlog control
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Maintenance procedures I
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Review of completed work and post maintenance testing
Findings
The inspector reviewed the licensees method of work control. WACP 10.1.1, J
Procedure for Control of Maintenance and Engineering Assistance Requests is ;
described in the administrative program for work control. This procedure
provides for reporting plant system material deficiencies; performing corrective ;
maintenance and repair of equipment at the plant; controlling the performance
of equipment modifications; initiating requests for various work permits; and.
initiating requests for engineering assistance or plant modifications. It
includes the administrative procedures for initiation, minimum planning,
authorization, testing and documentation of work. WACP 10.1.1 is implemented ;
by the work control center. During outages, the work control center (WCC) is :
operated by two senior reactor operators and two clerks. The,e persons are '
knowledgeable and well qualified for these positions. However, one area which
was considered to be inadequate was the method for identification cf rework in
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that it relies on the memory of personnel staffing the WCC. )
1
WACP 10.1.2, Equipment and Personnel Protective Tagging, is tr.3 procedure that
sets the requirements to ensure protection of equipment and personnel from
injury or damage during operation, test or repair . The inspector reviewed the
PTR-files and determined that work is being accomplished in accordance with
procedures. However, one problem was identified with the conduct of the D'
emergency diesel generator (EDG) idle speed inspection. The emergency service .
water (ESW) strainer ~ and supply header drains were inadvertently left open,
after moving-the boundaries on the equipment tagout for the ESW system. It
appears that the review performed to ensure that the new boundaries were adequate
to conduct maintenance and lack of a system lineup contributed to the problem.
The licensee made an operations department night order book entry and conducted
a formal critique ~concerning the problem. '
Conclusions
The use of a WCC appears to be a good method for coordinating work between
various. departments and for authorizing work and testing. Work is effectively
identified, prioritized and tracked.- Effectiveness is, in part, due to
significant. verbal interaction between various groups rather than to the
organization. Some problems have occurred due to the large volume of work ,
centrally ca irnlied and due to lack of attention to details. *
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5.3 E
3 uipment Records and History
Scope
The inspection objective was to assess maintenance history for plant components
and to determine the extent to which equipment records are used for trending,
planning and scheduling maintenance activities. Plant history records, NPRDS
data,
area.
and root cause analysis reports were elements used in evaluating this
Findings
Equipment history and records are accessed through a number of computers located
throughout the plant- .
These records are also available on microfiche. The
computer database can be accessed through a number of different files such as
component, system, or activity codes. The information from the various work
control forms is entered into the computer database by the WCC clerks. The
database appears to be accurate and up-to-date. However, the inspector had the
following two concerns in the maintenance history record area: a)-The nature
of the computer database is such that the plant's maintenance history records
may not be easily retrievable or in sufficient details to be of any value, b)
-Failure analysis and root cause evaluation are a recent program and not fully
implemented.
Procedure WACP 10.1.18, Control of the Plant Master Equipment List,-has been in
place for approximately two years. The master equipment list (MEL) is a computer
based file designed to be an unambiguous source for QA classification. The ,l
engineering information group updates the MEL The data, after entry, is
verified and second checked. Access- to the MEL database is through computer
terminals assigned to the various user groups.
Conclusions
The licensee has an effective method of maintaining equipment history and
records,. however the computer database may not be easily retrievable and some *
records contain minimal information. Failure analysis and root cause evaluation
programs are not fully implemented.
5.4 Work Planning
Scope
-The inspector observed maintenance activities to determine the adequacy of the
planning function in providing guidance in the areas of safety, coordination of
activities, technical accuracy, completeness of data packages, scheduling,.
special instructions, and exposure controls.
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Findinas
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The inspector reviewed various aspects of work planning in use by the licensee !
ano discussed the planning process.with work planners. Some considerations j
used for planning include the assigned work priority, work that can be efficiently :
performed with other scheduled work, and conditions that will deteriorate with l
time. A maintenance plenning checklist is provided with key attributes to assist
the planner in completing his task. The licensee currently has two mechanical
and two electrisal personnel performing the planning function. In general. !
most planning was adequately performed with effective use of the maihtenance e
planning checklist. However, a few problems were identified with the planning '
for some work. For instance, the inspector observed one work order (WRED 71838,
replacement of brushes on the UPS MG) in which the planning was inccmplete, ;
1.e., approved parts and not-applicable sections of the installation procedure ,
nad not been identified . Consequently, the work technician performed these-
elements of the planning task himself. In addition, several work request ,
packages in the mechanical maintenance area, ready for closure, were found to !
contain no checklist. Maintenance planners are taking some good initiatives
which enhance the performance of maintenance activities. Examples of this are -
inclusion of system drawings and polaroid pictures of the work and work area to '
assist the mechanics in determining the component location in the system.
Conclusions
The planning for both scheduled and nonscheduled work is generally well controlled ;
with bowledgeable planners directing the effert. A few examples of.in:omplete
or nonexistent planning were noted which appear to be due to inattention to
detail and the volume of work during the refueling outage.
5.5 Work Priorities
.
Scope
'The purpose of this inspection area was to evaluate the maintenance work
prioritization methods and criteria.
Findings
Priorities are assigned on the work request form using guidance provided in '
WACP 10.1.1, Procedure for Control of Maintenance and Engineering Assistance
Requests. Four levels of priority are used. The levels are designated as >
emergency, priority 1, 2, and 3. The guidance for determination of priority is '
adequate and useful to those individuals who make the determination. Review of
several work requests showed that the level of priority is being accurately 3
assigned using the guidance provided.
Work priorities are used in the work scheduling process to ensure that work
with higher priority receives the necessary level of attention.
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One weakness identified was the lack of use of probabilistic risk analysis (PRA) l
in determining work priorities. This is further di> cussed in section 4.3, Role
.of PRA in the Maintenance Process. -1
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Conclusions l
Work prioritization is performed by knowledgeable personnel, and is. adequately ;
determined. The program could be enhanced by including risk evaluation or PRA ;
factors in the process. ;
5.6 Work Scheduling
S_CPlle j
The purpose of this inspection area was to determine if maintenance scheduling l
and backlog controls are established and to evaluate the methods used to !
identify and control preventive, corrective and predictive maintenance.
Findings
Scheduling of maintenance during plant operation is coordinated by the work
control center (WCC). The WCC supervisor compiles a list of work requests that
are considered to be most important to plant operation and that can be worked
during normal operation. This priority list is used by the maintenance and I&C ,
departments for planning and scheduling purposes. Routine maintenance tasks
are discussed, scheduled, and tracked by the WCC, in -conjunction-with other
departments, during daily and weekly scheduled meetings. The -weekly scheduled
meeting is chaired by the planning = superintendent. -The purpose of the weekly.
planning meeting is to establish the next week's work schedule, discuss-upcoming ,
work, coordinate activities between departments, arrange limiting conditions ,
for operation (LCOs), and general problem solving discussion. Special. conditions
are applied prior to. entering an LC0 to better control,the maintenance activity, i
A list of high priority work items to be performed during short forced outages.
is also maintained for planning purposes. Maintenance and refueling outage ;
activities are' determined by the planning superintendent. A system window
. concept is used for scheduling maintenance activities. Periods of time are
determined for systems- during which all maintenance activities for that system
, are to be scheduled. it appears that this method-provides good administrative
? controls to prevent necessary redundant equipment-from being taken out'of
service. l
Conclusions
Maintenance scheduling for preventive, corrective and predictive maintenance = is "
identified and completed within the program guidelines. The WCC, during
operation, and the planning superintendent, during outages, adequately schedule
work activities. ,
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5.7 Backlog Controls
Scope i
The purpose of this inspection area was to determine the effectiveness of
backlog controls and the adequacy of the bases for deferral of maintenance
activities.
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Findings
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The licensee's backlog and monitoring system was reviewed. Important parameters -
related to maintenance are measured and tracked on a monthly report. These !
parameters are used to manage the maintenance department workload. Some of the
items tracked include non-outage corrective maintenance backlog greater than 3 .
months old, out of service control room instruments, preventive maintenance
items overdue, total number of work requests open and items awaiting final ,
administrative close out. Review of tracked data for the past year showed that
the maintenance backlog was being appropriately managed.
Conclusions ,
The licensee has a backlog monitoring system that includes a monthly trend I
report. The maintenance superintendent has been actively involved in monitoring
the status of backlog items and has the necessary resources to adequately manage
the backlog of maintenance items.
5.8 Maintenance Procedures *
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Scope .
The inspection objective was to assess the development and approval process,
the technical content, the method of control, and the periodic review process ,
of maintenance procedures.
Findings
,
The inspector reviewed the licensee process for maintenance procedure development ;
and implementation. Procedure development, control, review and use is controlled
by a number of- different utility procedures. AP-1.11, Procedure Writers Guide,
provides detailed guidance-for preparation of procedures. -AP-1.4, Control of. .
Plant Procedures, provides guidance for procedure initiation, review, approval,
and revision. A checklist is- also provided to aid the reviewer in completing
the procedure reviews. Other procedures provide guidance for special processes,
instrument maintenance, and surveillance tests.
The-inspector reviewed several preventive and corrective maintenance procedures.
.The procedures were technically correct and capable of being used. However,
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several procedures were not consistent with AP-1.11. For example, " cautions"
are used where a " warning" should be used, prerequisites and notes contain
action steps, signature blocks are not provided for QC, and some procedures do >
not have an expiration date assigned. The nature of these errors is such that '
they should not adversely affect the conduct of maintenance.
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- Computer programs are used to assist in tracking biennial procedure reviews.
The program to complete biennsal procedure review was judged to be functioning
well.
Conclusions
The maintenance procedure development, approval and control program elements
were well documented. More attention needs to be placed in ensuring consistent
procedure format.
5,9 Post Maintenance Testing
Scope
The inspection objective was to determine whether post maintenance testing
criteria were established, documented and implemented. The effectiveness of
the post maintenance testing program was assessed based on operational readiness
and evaluation of established acceptance criteria.
Findings
The Corporate Nuclear Maintenance Program, Chapter 11, Post Maintenance Testing,
describes the policy which is to ensure that plant equipment or systems are
capable of performing its intended function af ter corrective,. preventive or
predictive maintenance or af ter modifications are performed on that equipment
or system. Various procedures implement the policy and guidelines. NYPA
classifies post maintenance testing (PMT) as post-work testing (PWT). These
terms are considered equivalent for the purpose of this inspection report. The
post-work testing program is controlled by WACP 10.1.1, Procedure for Control
of Maintenance and Engineering Assistance Requests. This procedure includes
Addendum 9.4 which provides generic guidelines for determination of PWT recuire-
ments. The inspector was concerned that the use of generic guidelines incead
of a more specific procedure may result in inadequate PWT determination. Other
procedures discuss system engineer interaction and PWT scheduling.
The inspector reviewed several work request packages, located in the PWT pending
file, to determine the adequacy of PWT. In general, existing instrument surveil-
lance and operations surveillance procedures are used to verify operability of
safety-related equipment. No specific discrepancies were identified with the
-adequacy of PWT. The filing system currently suffers from a lack of space.
The licensee is addressing this issue in the form of plans to enlarge the WCC.
PWT requirements are determined by a senior reactor operator (SRO) and checked
by a second SRO. The shift supervisor (SS) verifies satisfactory completion of
tests and restoration of the component to service. The determination of PWT
relies upon the knowledge and personal skills of the SS and of the SR0s who
work in the work control center. System engineers are minimally involved in
the PWT program. Procedure PSO-1, System Engineer Program, formally empowers
the System engineer to assist in PWT determination, but, in practice, PWT is
primarily determined by operations personnel.
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Conclusions
The lack of system engineer input into the PWT determination and use of generic
PWT guidance instead of more specific procedures are considered to be a weaknesses
l- in the PWT program. The concern is that some PWT operational requirements may
not be recognized, especially during periods of extensive maintenance activities.
Nonetheless, the inspector recognizes that the operations department's personnel
which are responsible for the PWT program are knowledgeable and experienced and
, perform this function well. However, the success of this system is mainly
dependent upon personnel skills who are currently assigned to the task.
5.10 Review of Completed Work Documents
S.cgge
The objectives of this inspection area were to assess the process for licensee's
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review of work documents, general completeness of work documents, ard feedback
from review of the maintenance process.
Findings
WACP 10.1.1, Procedure for Control of Maintenance and Engineering Assistance
Requests, describes the administrative program for work control documentation.
This and various other procedures provide for review, storage and tracking of
records. A checklist detailing the documentation requirements is provided to
assist the responsible departments' administrative efforts. Although there are
several mechanisms to pr^ vide feedback to various groups, the feedback process,
. in practice, is usually accomplished through the morning planning meeting or
other informal methods,
A weakness was noted in the program, in that work packana dor mentetivt is it
tiaies incumplete. Some specific examples include: the final work package
review was not completed on PMWR 09137 and many procedure steps were not signed
off in the supporting procedure, MP-56.1, 600V Motor Control Center Maintenancs
and; Testing; WR 70568, CRD water pump A casing leak repair, was a rework but
was not identified on the computer list as such; not all work requests have the.
activity code number in block 6 of the work request form indicated; and the
e time required-to complete the work is not usually documented.
Conclusions
. The review of completed work control documents shows that additional attention
needs to be placed in completing the required work control packags documentation
and for conducting post work reviews. The program for providing feedback to j
various groups needs to be strengthened. ;
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6.0 PLANT MAINTENANCE ORGANIZATION
Scope i
The scope of this portion of the inspection was to determine the effectiveness !
and extent of control exercised by the maintenance organization for: (a) main-
tenance activities -(b) contract maintenance personnel, (c) deficiency
identification and control, (d) maintenance trending, and (e) support interfaces.
6.1 Control of Plant Maintenance Activities
Scope
The inspection objective was to assess the extent that the mechanical, ;
electrical, and instrumentation and control disciplines have established
controls for performing maintenance activities.
6.1.l~ Mechanical Maintenance
The inspectors interviewed personnel at various management levels and found -
them to be knowledgeable of their responsibilities. The staffing of the ,
mechanical section, in the maintenance department, appeared to be adequate for t
-an outage. They were sufficiently supplemented with contractor and temporary '
personnel and were adequately integrated into the department's work force. .The
inspectors reviewed the licensee's plant maintenance organization and the
maintenance and administrative procedures used to direct and control maintenance. -
Selected station maintenance procedures and work request packages were also
reviewed. Additionally, the inspectors observed work in progress on mechanical '
components, interviewed first line supervisors, and the maintenance mechanic
journeymen.
Specific observations are listad below:
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During the installation of internal parts on main feed check valve 34NRV-11A, 4
work was required to be stopped. It was discovered that the shaft could not be
inserted into the valve body due to a bushing that had been lef t in place during
di sa s sembly. The valve.in question was new and was being installed with a newly
written procedure. The work was supervised by the Vendor's Technical
Representative (VTR). When the inspector asked why the bushing had not been
removed,-the VTR stated he was responsible for the oversight. Subsequently,
the bushing was removed and the internal parts were installed in proper order
without further incidence. Although this was an isolated event, it appears
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that a firmer control of the VTR actions should be in place.
When observing the assembly of new interr.a1 parts for the outside main steam
isolation valve, 29A0V-868 a digital caliper (M-113), used for measuring the
dowel' pin in the assembly, was found to be without its proper identification
number attached, as required in Maintenance Department Standing Order MD-S0-04,
" Maintenance Department Measuring and Test Equipment Calibration Program",
' Revision 7, Section 7.'la. However, this digital caliper did have the proper
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usage log card in its carrying case. Upon further investigation, the same
deficiency was observed with another digital caliper (M-116). The licensee
took.immediate corrective actions and provided proper markings on the calipers )
in question. l
The JAF main technical library was inspected by the maintenance team. This
area was found to be neat and well organized, and centrally located in the
administrative complex for easy access to plant publications. The techrical
manual update program was reviewed by the inspector and found to be satisfactory. '
These manuals are located in a controlled area, and may be checked out when
neeoed. Maintenance personnel are aware of the availability of these manuals.
The inspector reviewed various completed maintenance work packages with respect
.to use of qualified personnel, prioritization, quality control (QC) involvement,
quality of documentation, equipment history, description of problems and
resolutions, and post maintenance testing. The inspector concluded on the
basis of the documents examined, that the licensee, in general, had adequately 1
addressed these items. However, the team also found that the " Action Accom- '
plished" and "Cause" sections of the work tracking form were not always utilized
to their fullest extent. Additionally, in one case, some areas in the work
package procedure that asked for specific information were left blank.
Specifically, when an adverse condition was found, during a check valve
inspection, the spaces for comments and for apparent cause were left blank.
Also, the signature of the cognizant engineer was missing.
Conclusions
The mechanical maintenance personnel appeared to be knowledgeable, displayed a
positive attitude towards their assigned tasks and were observed to be well
trained. Gentrally, good communications existed between maintenance personnel
and other groups, First line supervisors conducted daily meetings with their
workers to discuss daily assignments and to receive craftsmen feedback. However,
the licensee's review for completeness of the work packages needs to be ,
strengthened.
6.1.2 Electrical Maintenance
Electrical maintenance at JAF is controlled by a complex system of formal
procedures. Numerous approvals are required on all work requests before work
can begin. Most of the required approvals are obtained by a single action
within the Work Control Center (WCC). The WCC provides an approval chain that
includes representation from the interfacing disciplines such as QC, Safety,
Radiation Control,.0perations and Planning. During normal plant operation, the
WCC operates under the jurisdiction of Operations. During plant outages, the
WCC operates under the direction of the Planning Department.
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The Maintenance Department also has planners who review work requests and
perform preliminary work such as procurement of qualified parts. A properly
processed work request results in a work order with specific directions on work
to be done, procedures to be used, applicable sections or exceptions to the
procedures, and parts and tools necessary for the job. However, this procedure
is not rigorously followed. As an example, the inspector observed one work
order (WRED 71838, replacement of brushes on the UPS MG) in which the planning.
was incomplete, i.e., the approved parts had not been identified and the :
not-applicable secti W of the installation procedure had not been identified.
Consequently, these elements of the planning task were performed by the work !
te:hnician himself.
host of the written preventative maintenance work procedures cover a variety of
maintenance subtasks on a family of similar components. When a work request is :
initiated, it is necessary to determine what written procedures are applicable
and what sections of the procedures are applicable. When this portion of 4
planning is' neglected at the supervisory level, it defaults to the work level
technician. While this process displays some weakness, no instances were
observed where it had safety significance.
The maintenance department at JAF maintains a log of scheduled preventative r
maintenance tasks that have been delayed beyond their due date. The inspector
reviewed this log and determined that some preventative maintenance tasks on
MOVs had been deferred for more than a year past their due date. The licensee
responded to this. concern by showing that there had been no deferments of -
technical specification required surveillance or EQ related maintenance. The
MOV preventative maintenance had been deferred because the MOV maintenance ;
program was undergoing massive upgrade (as recommended by INPO) and the main-
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tenance on most MOVb was limited to plant outage. Additional training was also
necessary to implement the new procedures. The inspector noted that the number
of deferred tasks is rapidly being reduced. At the beginning of the outage
there were a total of 73 deferred tasks. At the time of the inspection 18 had
been completed and 30 more were scheduled prior to startup. The remaining
twenty-five tasks were scheduled af ter startup. ;
The inspector noted that the working interface between electr Nal maintenance
and I&C maintenance is not defined in any written document and that the interface
follows an unwritten general understanding between the persornel of the two
departments. Since I&C maintenance operates within a differtnt department there
is a possibility that some components could be overlooked by lack of a clear
jurisdictional definition. The inspector looked for evidenco of forgotten
components but found none. The missed annual maintenance of a 500 KW LPCI
inverter, which falls under I&C jurisaation, is discussed under Paragraph 6.1.3 y
below. The inter face between I&C and electrical maintenance is not a problem
for corrective maintenance since the WCC will assign the task to one organization
or the other.
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The working relationship between I&C and electrical maintenance appears to be
excellent and no instances were observed where the interface between electrical
maintenance and I&C had created any problem. There was, however, one instance
observed where work was not coordinated within the maintenance department. As- r
a result, the floor of the 125 Volt station battery room was painted too soon
prior to the battery service test for the paint to dry.
Conclusions
The inspector concluded that the electrical maintenance staff had a well
developed program for performing corrective and preventive maintenance.
Instances of imperfection in the maintenance procedures were overcome by a
highly-trained and competent staff. Imperfections in the maintenance program
are recognized and there is a continuing trend toward improvement.
6.1.3 IJstrumentation & Controls
The inspector observed work in progress in the instrumentation and control (I&C)
discipline and interviewed various maintenance craft personnel that were
performing the work. The inspector found that the I&C activities witnessed
were well planned, the craft personnel were knowledgeable of their required
tasks, and the steps outlined in their maintenance procedure were followed.
The I&C maintenance organization is a-separate group <hich operates outside the ,
maintenance organization, with its own Superintendent snd procedures. Some of
these are parallel to the procedures developed for the (electrical and mechanical)
maintenance department. Although the boundaries of jurisdiction between I&C
and the maintenance department, especially electrical, are not clearly defined,
the two organizations. appear to operate well and without confusion as to the
areas of responsibility. However, the annual preventive maintenance for the
LpCI inverter was not included in the I&C maintenance data base. In addition,
one requirement was. found to be implemented differently by the two organizations.
While reviewing the I&C computer printout of maintensnce required to maintain
qualification, the inspector found that a 10*4 time margin had been used to
perform that activity. The method-used to develop the schedule was consistent
with the I&C applicable procedure. However, the margin had been added to,
rather than. subtracted from the expiration date of the equipment's qualified
life but no components had passed the correct expiration date. Upon identifica-
tion, the licensee immediately initiated corrective actions. These included:
(1) revision of computer schedule; (2) review of schedule to identify overdue
maintenance, if any; (3) scheduling repl cement of 12 pressure switches prior
to refueling outage (only items with overdue date but already scheduled for
replacement per Modification No. MI-89-038); and validation of EQ schedule.
The inadequate scheduling of required maintenance constitutes a violation of
10CFR 50.49, Section (e)(5) which states that " Equipment qualified by test must
be preconditioned by natural or artificial (accelerated) aging to its end of
installed life condition... If preconditioning to an end of installed life
condition is not practicable,... The equipment must be replaced or refurbished
at the end of its designated life..."
- - - -
,__
,
e
,-
,' 41
_
In accordance with the NRC Enforcement Policy, 10CFR Pa~t ? Am adix C, the
violation is a severity level V (Supplement I). Howevei, occaua the safety
significance of the violation is minor, corrective actions wa - initiated prior
'
to the end of the inspection period, and the criteria specified in Section V. A
- of 10CFR Part 2, Appendix C, were satisfied, the violation is not being cited.
. (50-333/90-80-01)
--
The primary mechanism for identifying I&C corrective maintenance is the work
request which is submitted to the work control center for evaluation and
- scheduling. The procedure that controls the process for identifying, scheduling,
and tracking to completion of I&C maintenance activities, as in the case of
mechanical and electrical maintenance, is WACP-10.1.1. Evaluation of this and
other procedures relating to the performance of I&C maintenance activities
identified no programmatic concerns. Mxchanisms are in place for oversight of
in process activities by supervisory and management personnel; training and
periodic evaluation of technicians; periodic review of technical and
-= administrative procedures; ensuring that feedback from technicians and
supervisory personnel is obtained and factored in the preparation and the
revision of the procedures; ensuring that appropriate procedures, materials,
instruments and tools are used for the activity on hand. However, one area
which was found to be lacking and which needs management attention is the
control of materials. In this area, two observations illustrate the inspector's
concern.
In the first example one relay, which had been obtained from stock to replace
another damaged safety related relay, was returned to stock with a " Hot Used"
blue tag without appropriate recertification for use in safety related circuits.
The_ problem here was that the relay had been opened and used to recalibrate the
damaged relay- . Therefore, verification of its characteristics was necessary
prior to-its return to stock, as indicated by the responsible supervisor.
Discussions with QC personnel indicated that the tag would have not been
=
questioned and that the relay would have been recertified for use.
The second observation relates to some gaskets used in conjunction with two
-safety related diesel generator pressure switches. While reviewing the work
package, the inspector observed that the gaskets were part of a larger shipment
(report of material received RMR #43808) which included 25 of those gaskets,
five seals and'three more types of gaskets. Since the material identified on
the RMR appeared to exceed the scope of the repair job, the inspector asked the
entire scope of work. The inspector determined that the gasket had been obtained
from a maintenance supervisor, rather than from the warehouse. Further
investigation revealed that a large quantity of materials, including materials
used in safety related applications, are purchased for Direct Turnover, i. e.,
materials are procured and, after receipt inspection, are turned over to the
requesting organization, rather than stored in the warehouse until needed. The
major concern here is that the procedures that control the storage, distribution,
and restocking of safety related materials no longer apply. While it is true
,
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. 42
that no limitations are imposed on the usage and handling of materials, once
they are released from the warehouse, in general, the probability of damage is
minimal if used within a reasonable amount of time. The same cannot be assumed
when stored for relatively long periods in a desk drawer, Storage time is
particularly important for those materials which have a limited shelf life.
Conclusions
The I&C organization has a well developed program for performing preventive
and corrective maintenance. The program also appears to be parallel to that
of the maintenance organization. However, the use of independent procedures
and data base can lead to inconsistent results as evidenced by the findings
identified. Control of materia's for safety related applications is a concern
which needs management's attention. The problem is particularly noteworthy for
materials purchased for direct turnover.
6.2 Control of Contracted Maintenance
Scope
The objective of this part of the inspection was to assess contractor support
to maintenance activities. Specifically, the assessment included selection and
training, monitoring of performance, accountability, and quality control.
Findings
At the time of the inspection, the facility was shutdown with extensive main-
tenance and modification work scheduled for completion during that period. For
this purpose the licensee had secured the support of approximately 90 temporary
and contractor personnel. Discussions with personnel from the various mainten-
ance organizations, Quality Control, and 'Iraining revealed that the licensee,
during normal plant operation, utilizes permanent JAF employees for the every
day maintenance activities. During periods of heavy work load, such as refueling
shutdowns, it does resort to contractors and temporary help. However, these
personnel are generally used in a support capacity, as-part of a maintenance
team, where continuous supervision is exercised. One exception to this was
found in the Quality Control organization, where contractors work independently,
and in one case a contractor was performing supervisory duties.
As a result of the licensee's general policy, except for general training,
contractors and temporary employees receive little or no training, prior to
their assignment to the group for which they were hired. With respect to the
effective utilization of contractors and temporary personnel, the licensee
relies heavily on previous experience and training from other employers and
organizations. In the case of the quality control supervisor, he is a regular
hire and has performed quality control functions at JAF for many years.
Observations of I&C work in progress confirmed the statements by the interviewed
personnel. In general, contractors and temporary technicians were used in teams
of at least two persons, with the permanent JAF employee responsible for
directing and signing the activities prescribed by the particular procedure
being used, j
l
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,.
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... 43
Conclusions
,
The licensee appears to make effective use of contractors and temporary personnel.
While there may be some concern about quality of work performed or accepted, as
in the case of QC personnel, because of their unfamiliarity with plant specific
procedures, no examples of adverse quality maintenance work were observed.
'
!
6.3 Deficiency Identification and Control System
- Scope =
The objectives of this portion of the inspection were to determine the licensee's
process for deficiency identification, the personnel's understanding of this
process, and the ease for effectively reporting deficiencies. .
Findings
The deficiency identification system consists primarily of two mechanisms: the
work request (WR) and the adverse quality condition report ( AQCR). The work
request, governed by Work Activity Control Procedure WACP-10.1.1, is used for
reporting plant system material deficiencies and for performing corrective
maintenance and repair of equipment. Quality Assurance Procedures QAP-15.2 and
QAP-16.1 provide.the mechanism for identifying, reporting, evaluating and
dispositioning of non-conformances and adverse quality conditions.
All licensee.and contractor . personnel involved in work activities related to
operation, maintenance and modifications at the facility are responsible for
identifying ~ deficiencies and conditions which are adverse to quality and to the
safe operation of the plant. However, while all maintenance personnel were
familiar with the work request process and satisfactorily implemented WRs for
equipment deficiencies, they' expressed confusion on the initiation and
implementation of the AQCR process.
l
~0bservations of maintenance activities and discussions with maintenance craft
indicate that, in practice, deficiencies, including nonconformances, when
identified, are reported.to the supervisor verbally and/or by means of work
request *, Although examples of AQCRs prepared by engineering were found, AQCRs
- are nomily prepared by the Quality Control organization which is responsible
.for the monitoring and dispositioning of nonconformances.
Once a deficiency has been identified, regardless of the method used for
reporting it, if it does constitute a nonconformance, an AQCR is ultimately
written. At that point, the mechanisms which are in place for evaluating and
. tracking to resolution of nonconformances and which are contained in the
applicable Quality Assurance procedures come into action, The reasons for the
I
above are that: (1) all work requests are routed through the work control center,
the staff of which includes a quality control person; and (2) a copy of the
work request is always sent to Quality Control for evaluation and scheduling of
required monitoring Activities. However, the weakness in understanding non-
conformances could impair their recognition.
l
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t,
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Conclusions
The program, as described in the procedures, for identifying and reporting
deficiencies and nonconformances and for requesting maintenance, was adequately
implemented. Implementation of the mechanisms for resolving deficiencies also
was found to be adequate. However, some weakness appears to exist in the
identification of nonconformances. This may be primarily due to a lack of
understanding of the difference between a deficiency and a nonconformance, and
inadequate training of all plant personnel in the Quality Assurance procedures.
6.4 Maintenance Trending
Scope
The objectives of this part of the inspection were the review of the maintenance
trending program procedure development, of systemic versus specific corrective
actions, of root cause analyses, and rework evaluation.
Findings
Plant Standing Order PS0-1 requires that a system engineer be responsible for
collecting and evaluating data relative to the design,' operation and maintenance
of the systems assigned to him. The intent of the requirement is to make the
system engineer the focal point for particular systems and components to
ultimately improve the overall performance and reliability of the plant.
Accordingly, one of the responsibilities of the system engineer is to trend
-important system parameters so that he can evaluate system performance and
identify early stages of deterioration in components and systems. The
engineering department also includes a performance group with specific project
responsibilities. In addition to the above, approximately three years ago, the
licensee initiated a program to track failures of systems and components. The
program utilizes a computer based data bank, which includes industry as well
as plant specific failure reports, to analyze the component failures and'
. establish, among other things, the adequacy of the preventive maintenance
procedure.
Although programs have been established for early warning and prevention of
system and component- failures, their implementation appears to be lacking
somewhat. As a result, maintenance activities tend primarily to fall within
the area of corrective maintenance work. Some of-the reasons for this are, the >
limited scope of the various programs which are in place, the newness of some
programs, and the lack of coordination between various groups, programs, and
data bases. For instance, the program initiated three years ago te analyze
component history and adequacy of maintenance procedures is limited to critical
systems and components. As a result, although 22 " critical systems" were
analyzed, not all of the safety related equipment is addressed. In addition,
this program is not-tied in any way to the Master Equipment List (which has its
own data base) and has a limited life. Therefore, when the program is completed
and its objectives are attained, no further trending is planned to verify
assumptions and ensure acceptability of results.
- - - - - - - - - - - - - - -
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, 45
Root causs inalysis is addressed in Administrative Procedure AP-8.1 and Quality
Assurance i rocedure QAP-16.1. Both procedures identify the need for such
analysis, e pecially in the case where significant adverse quality conditions
are identifi$d, as specified by the latter procedure. With respect to corrective
maintenance, iiscussions with system engineers indicate that, within the scope
of this portit', of the inspection, root cause analyses are appropriately
conducted to p,svent recurrence and corrective actions are followed to ensure
correctness of .nalysis results. One example of properly conducted roct cause
analysis is the ,ngoing evaluation, including laboratory tests, to resolve
problems _experien ed with the instrument air system. However, with respect to
preventive mainte ince, root cause analyses appeared to be minimal and limited'
to the cataloging sf components' failure modes in computerized data bases.
Conclusions
Programs are in place for performance of maintenance trending and root cause
analysis. However, the implementation of these programs is somewhat lacking
because of the limited scope of the current efforts. As a result the licensee
is tending more toward reactive fixes.
6.5 Support Interfaces
The inspector examined and reviewed the licensee's interface between the
maintenance organizations and other departments, inc.uding Operations, Quality
' Control, and Engineering.
The focal point for all maintenance and modification work is the work control
center (WCC) where all work requests, regardless of the originating organization,
are funnelled. The WCC, which falls under the responsibility of Operations,
reviews all work requests and assigns primary responsibility for execution of
the task. The procedure which governs the activities is WACP-10.1.1, titled
Procedure for Control of Maintenance and Engineering Assistance Requests.
Besides the WCC formal as well as practical lines of communication between
various organization are established through the daily and weekly schedule
meetings. These meetings involve supervisory personnel from the various plant
organizations.
Through the observation of in process maintenance activities, attendance morning
and scheduling meetings, and discussions with personnel in the various organiza-
tions, the inspector concluded that effective. communication exists among the
maintenance crganizations (I&C, Electrical and Mechanical) and between these-
and.the support organizations. Communications appear to work in both directions
with maintenance being used,- for instance, by engineering for data collection
and transfer; engineering being used for problem solving. Quality Control (QC)
is involved in all activities, in that a member of that department is part of
the WCC staff and reviews all work requests. In addition, a copy of all work
requests is sent to QC for scheduling its activities.
..
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. 46
The only example iJentified by the team where effective communication was not
used was work reglest No. 70213. In this case, the originator reported that
loose screws had been observed on an EQ junction box. The work request was
marked to'be minor and added to the list of minor maintenance work whh;h is
tracked separately. Since the deficiency involved a Class 1E junction box in
the. reactor building and, therefore, exposed to moisture, engineering should
have baen consulted for proper scheduling of the required maintenance.
Conversely, good communication was observed between engineering and maintenance,
as in the case of the HPCI modification being performed, during the current
outage. The modification involved Engineering, I&C and Mechanical maintenance.
Since the work being performed was in a high radiation area, prior to the
execution of the various tasks, the technicians and engineers met to discuss
problems encountered and their resolution.
7.0 MAINTENANCE FACILITIES, EQUIPMENT AND MATERIAL CONTROL
Scope
The objective of this portion of the inspection was to assess the plant's
maintenance facilities and controls over maintenance equipment, tools and -
materials to determine how well they support the maintenance activities. The
I
following areas were examined during this inspection:
-
Maintenance facilities and equipment
-
Materials controls
-
Maintenance tool and equipment controls ,
-
Control and calibration of meter and test equipment
The objective was attained by plant walkdowns, document reviews, and interviews
conducted with. supervisors and personnel in associated areas.
Conclusions
The plant layout and personnel placement of the maintenance facilities were
determined to permit efficient operation of maintenance activities, The layout
-of the maintonance facilities and space utilization were organized and
controlled, and the flow of material and equipment throughout the plant was
accommodated by the facilities.
Administrative policies and procedures adequately control the specification,
procurement and receipt inspection of maintenance related materials ind
equipment. Except as described in Section 6.1.3, safety related materials are
adequately identified to ensure proper procurement, storage and issue for its
intended use. The warehouse material tracking system is adequate for maintaining
inventory and for accountability of materials received, stored and issued from
the warehouse. The procurement program is implemented to ensure that materials
intended for maintenance activities are correctly specified and received in a
manner which support established maintenance work schedules.
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, 47
Maintenance tool and equipment identification, storage, and issue were
controlled. Personnel performing calibrations were properly trained, and
calibration standards were ascertained to be traceable to the National Bureau
of Standards.
7.1 Maintenance Facility And Equipment
A tour of the I&C and Maintenance facilities was conducted.to assess the degree
to which the facility layout and its accessibility provided for_ efficient
i
maintenance operations.
The offices of the I&C Superintendent and Supervisors are located in the
administration building,- as are the I&C main tool room and the electrical
storage room. The I&C hot shop, where potentially contaminated equipment is
stored, is in the turbine building. The maintenance tool room is in the turbine
building within easy access to the maintenance Supervisors' offices in the same
building. The office of the Maintenance Superintendent is located in an annex
to the administration building, but in proximity to the maintenance facilities.
Support organizations work areas, including health physics and quality assurance,
are close by or easily contacted by telephone or by the facility's page system.
Areas are established as needed to-support specific maintenance and modification
activities, such as the turbine maintenance project and the emergency diesel
generator maintenance project which were conducted during the current refueling
outage. The inspector observed that the space provided for these projects was
adequate to accommodate the associated activities. The inspector also noted
that specific areas were allocated for the storage of scaffolding in the plant.
7.2 Materials Controls
The adequacy of administrative policies and procedures were reviewed with
respect to the effective control of material (components, spare parts, and
consumables) used in maintenance, beginning with material requisition and
extending through material -installation or use.
The inspector determined that adequate guidelines have been established for
ensuring that appropriate specifications are identified in the procurement of
- materials, and that the required certificates are provided with material that
is delivered to the site receiving area. Procurement documents, including
,
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Procurement Requisition #018858 for replacement seal set #0701-217 used for 23
MOV-16, were reviewed to ascertain that administrative policies and procedures-
are being complied with. The Procurement Document Technical Review Summary
confirmed that applicable requirements are addressed by the purchase documents
including receipt inspection, testing, design requirements, applicable
specification, seismic and environmental qualification.
A walkdown of the site warehouse was conducted and warehouse and quality control
(QC) personnel were interviewed to assess the adequacy of the facility regarding
support of the maintenance effort. The warehouse provides an ANSI N45.2.2 Level
B storage capability for parts and consumables. The licensee stated that, at
present, there is no Level A storage capability and that no present need exists
for that type of storage. However, the new warehouse, currently under
construction, will provide space for Level A storage. An area of the existing
warehouse is allocated to quality control personnel for the performance of their-
receipt inspections prior to placing the materials in the assigned warehouse
storage area. Materials are not placed in the general issue area until QC has
attached an inspection tag, indicating that receipt inspection requirements
have been complied with. Warehouse inventory'is controlled and tracked via a
computerized data base. Special storage requirements, such as shelf life and
EQ requirements, are identified, as are code class, maximum and minimum
inventory levels, and inventory on hand. Automatic reordering is initiated
' when inventory drops below an established minimum level. Material issued from
the warehouse is controlled by identifying the individual to whom the material
is issued and the work request number to which the material is to be applied.
7.3- Maintenance Tool and Equipment Controls
A tour of the maintenance tool room was conducted to assess the adequacy of the
control maintained by the licensee over tools and equipment stored in the tool
room. Tools and equipment are controlled by means of a computer based tracking
system which identifies the equipment by a unique number, the calibration
frequency, calibration date, and calibration due date. The majority of
calibrations are performed by a vendor who picks up and returns the tools on a
scheduled frequency. The tool room attendant is qualified to perform specific-
tests, such as load tests of rigging equipment. He is also responsible for
maintaining all records of vendor calibrated and internally calibrated equipment.
The inspector reviewed the data base for selected equipment and found that the
records were complete and that they identified the current status of that equipment.
.The inspector observed that the data base regarding rigging equipment, ID# 00167,
was updated at the time the equipment was returned to the tool room and that
the current status of the equipment, including its availability for use and its
current storage location, was identified. Additionally, the inspector observed
the performance of load testing of a new chainfall, rigging ID# 00255,
S/N CB-1279 DBW. The test was performed by the tool room attendant who, sub-
sequent to the testing operation, identified the equipment with permanent marking
and +.ntered the appropriate information into the computerized tracking system
data base. The dynamometer used to perfort the load test, M&TE #M-155,
S/N AP 29841, was used within its calibration period and the equipment used to
calibrate the dynamometer was determined to be traceable to the National Bureau
of Standards.
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. 49
7.4 Control and Calibration of Meter and Test., Equipment
A tour of the I&C main tool room, relay room and hot shop was conducted to
assess the adequacy of the control and calibration system incorporated by.the
licensee for the equipment stored in those areas,
' The inspector determined that- a color coded tagging system is in place which
identifies the calibration. status of each piece of test equipment. Additionally,
a control' usage log for each piece of equipment identifies each job on which
the equipment is used. Test equipment is identified with a unique number which
is also used on the associated tag and control log. The information is included
i
in the equipment computerized tracking system.
Test equipment calibration is performed both in-house and by a vendor. In-house
calibration is performed by the I&C tool room attendant who is qualified to
perform specific calibrations. Calibrations for which the attendant has received
no training are done by the licensee's vendor. Calibration equipment used for
both in-house-and vendor calibrations was determined to be traceable to the
National Bureau of Standards. Calibration records of selected I&C_ equipment
were reviewed and found to be complete. In addition, usage logs indicated that
the equipment had been used within its current calibration period. Issuance of-
test equipment is the responsibility of the shift tool room attendant.
8.0 PERSONNEL CONTROL
Scope
The objective of this portion of the inspection was to determine the extent to
which personnel are trained and qualified to perform maintenance activities.
To make the asse'$nrnt the following areas were examined:
-
Staffing control
-
Training
-
Testing and qualification
-
Current status
The assessment was based on interviews, observations at the training facilities,
observations of field activities, and review of training records.
Conclusions
The licensee's training program is approved by INP0 and the apprentice program-
is also approved by the State of New York. Personnel training records are
arranged in a manner that permits a reviewer to quickly determine an individual's
current training status and are maintained in a dedicated area of the trait 'ng
facility. The training laboratories (mechanical, electrical and I&C) were very
well equipped and included appropriate mock-ups. The instructors were
knowledgeable in their respective discipline.
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8.1 Staffing Control
Assessment of this area was based on interviews with the instrument and controls
(I&C)'Superint'endent and the Assistant to the Maintenance superintendent.
promotion is done from within the company and, when'possible, within the depart-
ment. All of the I&C supervisors have advanced through various levels in the
department and 3 of E maintenance supervisors were promoted from-the bargaining
'
unit. The turnover race is very low, less than 1*4 per year, and has resulted
in an experienced group. The average years of experience are approximately
8 1/2 years and 9 1/2 years, for the mechanical and electrical maintenance
departments, respectively, and approximately 7 years, for the I&C department.
During outages, a 60. hour per week work schedule is followed. However, the
schedule reverts back to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week during periods of normal operation.
8.2 Personnel Training
The licensee's training program is divided into two parts, an apprentice program
and a continuing training program which applies when the apprentice program is
completed. The training follows the INP0 guidelines and is approved by INPO.
Additionally, the apprentice program is approved by the State of New York.
The apprentice program requires approximately 26 to 28 weeks to complete. The
licensee requires that it be completed in 4 years, but it can be completed in
less than 4 years. For this purpose, individuals are scheduled for the training
approximately 1 week in each 6 week period, or approximately 6 to 8 weeks per
year. The program includes fundamental courses of basic theory in the various
disciplines and BWR Technology, theory in a specific discipline, oracticed skills
which include laboratory work and/or sessions in the plant, plant specific
systems, and un-the-job training.
A " Jury of Experts", made up of a minimum of three members, establishes the
program and updates it as it deems necessary, based on plant experience and
needs. The jury is comprised of members in each of the following categories:
- '
Supervisor
-
. Training Instructor
-
Plant Worker
The committee must meet at least once a year, but it may convene more often, if
the need arises.
Progress of individuals is documented and tracked by the training department's
computerized tracking system. A training tracking matrix is generated every 6
weeks (each training cycle) by the training department who distributes copies
to thel departments supervisors. The matrix lists the individual's records and
is used to determine their current status in the program (apprentice, journeyman,
etc.). . Specialized training is provided by in-house training instructors and
by vendors, who are expert on the specific subject, on an as-needed bases.
......_.__._ _
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. 51
Selected records of NYPA employees and maintenance contractor employees were
reviewed and were determined to be complete and current. The records showed
that those individuals had received training in specific activities being
performed during the outage.
The inspection included a tour of the three training laboratories (Mecha* ical,
Electrical and I&C) in the facility. The laboratories are used to pro,ide
general, hands-on training and, additionally, training for more comp'.icated,
non-routine maintenance projects. The' laboratories were observed to be well
stocked with mockups and equipment to simulate plant conditions.
8.3 Testing and Qualification
Training.and qualification of- Power Authority employees,. including instruction,
testing and documentation of each individual's training status, is administered
by the licensee's training department. The course content is defined by the
apprentice and the continuing training programs, as established by the " Jury of -
Experts."
Training of contractor maintenance personnel is administered by the Contract
- Services group, but the licensee's training department provides specialized
training in selected cases,
On-the-job monitoring and supervision by licensee staff are the methods used-
by the 1icensee to assure that the desired level of contractor performance is
achieved.
" - - - -
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_________
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.4
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.
APPENDIX 1
INDIVIDUALS CONTACTED
New York Power Authority
R,-Archer I&C Tool Room Attendant
- R. Baker Maintenance Superintendent
A. Brais Procurement Engineer
- P. Brozenich Waste Management General Supv.
B. Carlson Preventive Maintenance Supervisor
P. Clements Contract Services - Civil /Struc Supv.
E. Conger Warehouse Supervisor
J. Conroy Quality Assurance Supervisor
- J. DeRoy Assistant to Maintenance Supt.
- *'P. J. Donahue PMTF Manager
- W. Fernandez Resident Manager
- T. J. Herrman Systems Engineering Supervisor
E..Hyne Shift Supervisor
J. Johnson Quality Assurance Specialist
N. Johnson Mechanical Maintenance Planner'
S. Juravich I&C Surveillance Coordinator
- H. N, Keith I&C Superintendent
- R. Lallman Director BWR Operations & Maintenance
- T. Landers Superintendent Material Control
J. Leach Maintenance Tool Room Attendant
- D. Lindsey Planning Superintendent
- R. Liseno Superintendent of Power
- R. A. Locy Operations Superintendent
J. Lyons Performance Engineer
D. Maclean. Journeyman Electrician
R. Maki Work Control Center Supervisor
J. Marris I&C' Lead Technician
K. Moody Equipment Qualification Supervisor
- E. Mulcaney Sr Technical Advisor
D. Nacamuli I&C Maintenance Supervisor
- R. A. Patch Sr. Quality Assurance Specialist
M. Reno I&C Maintenance Supervisor
- 'G Tasick Quality Assurance Superintendent
- G. J. Vargo Rad. & Env. Services Superintendent
- V, M. Walz Technical Services Superintendent
- J. Wierowski Technical Training Supervisor
. . - - - - - -
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- % ited States Nuclear' Regulatory Commission. .i
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'{ ,* ALL.DellaGreca
. Sr. Reactor Engineer- 1
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^*'H.!Graye Sr. Reactor: Engineer-; *
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- :- Haroldsen- Inspector - EGG-
yw c..'R. .G; K~.~;Hunegs .
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- Resident Inspectn. t
, . - * J.1CL Linv111e= Project Branch Chief- _l
P4J '*'R. X McBrearty; . Reactor Engineer . l
M * B. G MartinL Inspector AMSEC ~
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- 1RL-Platse.. ResidentfInspector= j
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- W' Schmidt; ' Sr. Resident Inspector- i
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APPENDIX 2
,
SUMMARY OF WEAKNESSES
-Weakness - A potential problem or condition presented to the licensee for
evaluation and corrective action as appropriate.
--
Plant walkdowns indicate that there are areas in the plant where house-
keeping and handling of hazardous materials and should be improved.
(1,2, 4.5 & 4.6) *
--
Identification of equipment and plant locations is lacking. (1.2)
--
Vie of equipment restraints.without seismic analysis may be indicative of
patentially inadequate design reviews. (1.2) ,
--
A -)redictive maintenance program is partially developed and implemented.
(3.4 & 6.4)
--
The program for equipment upgrade, for replacement of plant components and
for evaluating effects of plant aging could be strengthened. (3.7)
--
Interaction between performance and system engineering is not described
by procedure. (4.1)
--
Definition of responsibilities for engineering support of maintenance is
not well documented in some cases. (4.2)
--
Risk based concepts or PRA are not presently considered in the planning,
scheduling, and prioritization of the maintenance process. Management
goals _in the use of PRA have not been established. (4.3 & 5.5)'
!
--
Criteria-for establishing QC inspection hold points in work packages are
not defined by procedures. (4.4)
--
The method for identification of rework, particularly during periods of
~ heavy work load is not under documented control. (5.2)
--
Equipment maintenance history could be enhanced by more attention to
details, by a more detailed data base, and by full implementation of
failure and root cause evaluations. (5.3 & 5.10)
--
Several examples of maintenance activities wi a incomplete or no planning
were identified. (5.4)
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. Appendix 2 2
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Guidelines for procedure development could be improved to ensure a
consistent format. (5.8)
--
More specific procedures, which include the system engineer's input, should
be considered for post maintenance testing. (5.9)
<--
Parallel procedures and data bases for the electrical and I&C departments l
were noted to be inconsistent in approach or definition of-boundaries of !
responsibility (6.1.3) i
.I
--
The direct turnover of safety related materials to supervisors presents
the situation where the material is no longer under warehouse control
(6.1.3).
- - . Not all personnel have a' clear understanding of the difference between
deficiency and nonconformance. (6.3) !
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- Numbers between parentheses refer to report sections,
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