ML20077F757
| ML20077F757 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/13/1991 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-91-2170, NUDOCS 9106200187 | |
| Download: ML20077F757 (7) | |
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1 GPU Nuclear Corporation 4
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Forked River. New Jersey 087310388 609 971-4000 Wr:ter's Direct Dial Number.
June 13' 2170 1991 C321 U.S. Nuclear Regulatory Commission ATTN:
Document Control Dask Washington, DC 20555
Dear Sir:
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Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 50-219/91-06 This letter is being written as required by the Notice of Violation documented in Appendix A to NRC Inspection Report 50-219/91-06. Attachment 1 to this letter contains the GPU Nuclear response to the identified violation If any further information is required, please contact Mr. John Rogers at (609) 971-4893.
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u J hnJ. E}a ton V ce Pre:I dent & Director yster C:eek JJB/JJR/jc Attachment cc:
- Administrator, Region I Senior NRC Resident Inspector Oyster Creek NRC Project Manager 9106200187 910613 PDR ADOCK 05000219
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GPU Nuclear Corporation is a subsid ary of General Pubhc Ut;ht,es Corporation
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i R20uirement Technical Specification 6.8.1 requires written procedures shall be established, implemented, and maintained that meet or exceed the requirements of the Nuclear Regulatory Commission's Regulatory Guide 1.33. Regulatory Guide 1.33, includes Administrative and Maintenance procedures.
Violation 1.a Work Management System Procedure A000-WMS-1220.08, " Job Order," Section 4.6, Preparation of Job Order's for Corrective Maintenance Activities, Step 4.6.12.5, requires " Work Sequence - provides the detailed step-by-step instructions necessary to perform the work..."
Contrary to the above, on March 5,1991, corrective maintenance was performed on the recirculation pump motor MG set pneumatic speed control using Job Order No.
21331.
The work sequence portion of this job order only reference the vendor manual and did not provide the detailed step-by-step instructions necessary to perform the work.
GPUN Response to lug GPU Nuclear concurs in the violation, as delineated below.
The violation was caused by a lack of uniform application of the phrase
"... instructions necessary to perform the work..."
It is the GPUN position that the "necessary instructions" for a senior technician with many years of experience are far less than the "necessary instructions" for a junior technician with little experience in an assigned task.
A000-WMS-1220.08, " Job Order", section 4.6.12.5, does indicate that the Work Seouence (portion of a Job Order) "...provides the detailed step-by-step instructions necessary to perform the work in a correct, efficient and safe manner...", however, sections 4.1.2, 4.6.3 and 4.6.10 also pertain to the level of step-by-step detailed work instructions to be provided.
Section 4.1.2 in a NOTE states:
" Detailed step-by-step work methods, directions, or procedures may not be required for all maintenance and modification work if the work can safely be completed utilizing the skills normally possessed by qualified maintenance personnel."
Two On the Job Training (0JT) tasks have been developed to promote the learning of the relevant skills, o
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.' s Section 4.6.3 states:
"The Job Planner will determine the appropriate level of planning by:
Reviewing the work request problem description and/or discussing with the work request originator.
Reviewing associated technical documents.
Reviewing any applicable work procedures.
Performing walkdowns and, Consulting machinery history records."
These requirements were addressed in this case as:
1.
The work requestor described the necessary maintenance with respect to the vendor manual, with the concurrence of the maintenance superintendent.
2.
The superintendent and job planner realized that vendor manuals W preventive maintenance tasks which were available were sufficieo h do the work.
3.
Only one of four specifically qualified individuals was assigned to do the work.
The individual assigned also provided on the job training to a junior technician to assist in the 0JT process.
4.
Two very specific preventive maintenance tasks to be implemented concurrently were also provided to the technicians.
5.
Machinery history cards were accessed by the technicians for calibration data as suggested by their inclusion in references in the job order.
Section 4.6.10 says:
"The Job Planner will list attachments (documents which must be used), and references (documents which may be used), to perform the job order work, t
The references of the job order included the vendor manuals required to perform the work.
Therefore, in this instance, the instructions necessary to perform the maintenance were provided as required.
However, GPUN concurs that the instructions may not have been adequate if a lesser-experienced technician had been assigned.
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To preclude the recurrence of this ty)e of event, the job planners will be briefed on the need for detail in specifying step H stop instructions.
Full compliance will be achieved by June 30, 1991 wher de requisite job planner briefings will be completeri.
Violation 1.b Work Management System Procedure A000 WMS-1218.03,
- Work Procedure Control."
Section 4.9, Use of Selected Sections of Preapproved Procedures, Step 4.9.1.3, requires "If any precautions, prerequisites, or acceptance criteria in the 4
procedure are made not applicable to specific work, the extent of such an exception shall be detailed in a work controlling document, and a Group Shift Supervisor / Shift foreman (GSS/SF) shall concur with such determination by signing the cover sheet of a working copy of the Work Controlling Documant (Job Order.
- etc.)."
Contrary to the above, during the observation of work, on March 4,
- 1991, conducted in accordance with Job Order No. 29318, " inspection of the containment spray pump motor splices," a precaution and limitation in the preapproved t
procedure for - the-performance of the work was no longer applicable to. the specific work due to plant conditions and was not implemented. ~ The group shift supervisors / hift foremen concurrence with this action was not indicated by his signing the cover sheet of a working copy of the job order, the work controlling document.
GPUN Resnonse tq,Lh GPUN concurs in the violation as delineated below.
This saccific job order had been written to perform maintenance during the operat'ng cycle, er.d included all Technical Specification required precautions to allow maintenance while at power. Subsequent maintenance planning allowed the -
work to be performed during a refueling outage when the containment system was not required, therefore, limitations on de-energizing the system were no longer a)propriate.
This was discussed by tce maintenance supervisor with the Group s1ift Supervisor, and a correct decision to allow work to proceed was made. The Group Shift Supervisor did not sign the Job Order documenting his approval prior-to 1110 wing work to commenco.
1he procedural requirements addressing changes to approved Job Orders will be-made required reading for all ' Electrical Job-Supervisors, -Group Operating -
Supervisors, and Group Shift Supervisors. Full compliance will be achieved with the completion of the required reading, presently projected for the third quarter of 1991.
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.~ s Violation 1.c
%ter Creek Station Procedure 105, Condt.ct of Maintenance, step 5.20.4 requires,
-At least quarterly Operations and Plant Materiel shall review shall outstanding MCF Work Requests Work Requests to assess the impact of the maintenance backlog on plant operations and on the plant material condition, and evaluate the rank of the MCf Work Requests."
Also, Work Management System procedure A000-WMS-H00.08, Job Orders, step 4.10.1.1 states, ' Plant Operations will review all outstanding Work Requests / Job Orders at least quarterly to assess the impact of the maintenance backlog and, in conjunction with Plant Maintenancc, evaluate the ranking of the Work Requests / Job Orders."
Contrary to the above, on March 12, 1991, it was determined that no written guidance exists for the quarterly review and rank evaluation, no review has been documented, and there was no verification that s review had been performed.
M Response to 1.c GPUN concurs with the violation as delineated below:
Work Requests are reviewed for impact on plant operations and material condition for the following conditions:
1.
New Work Requests are reviewed daily against the open maintenance backlog, utilizing component codes, to discern recurring problems, deteriorating conditions, or duplicate deficiencies.
2.
Backlog items are reviewed to coordinate work activities in support of the plant's seasonal maintenance requirements.
3.
Systems with large or increasing backlogs are evaluated and work l
stems integrated icr scheduled system /componem outages.
This coordinates corrective, preventive, surveillance, and capital work.
4.
An updated prioritized inventory and baseline schedule for forced outages is maintained and adjusted to support major work which would be on the " critical path."
5.
Established surveillance and preventive me.intenance tasks are used as a schedule to which corrective maintenance jobs are integrated to develop a two week look ahead.
Oyster Creek Procedure 105 and Work Management System Procedure A000-WMS-1220.08 specify that the quarterly review is a minimum. Of the items listed above, No.
1 is performed daily; No. 5 is performed weekly; Nos. 3 and 4 are performed continually; and No. 2 is adjusted to seasonal requirements. GPUN concurs that this process of listing, evaluating, ranking, and scheduling is not documented.
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However, the significant reduction in the size of the maintenance backlog is documentation of the efficiency of the process, and the attendance of NRC inspectors (both Region based and Resident) at the various planning meetings serves as regulatory overview that the process does take place.
No further corrective actions are required for full compliance.
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s Violation 1.d Work Management System Procedure A000 WHS 1220.14, " Preparation. Review and Approval of Work Procedures," step 4.1.8 states, "for practical reasons, to preclude a Job Order (J0) from being unnecessarily complicated and made equivalent to a Work Procedure, work steps or other requirement in the referenced and preapproved documents should not be copied into a JO, but rather referenced in the J0.*
Contrary to the above, on March 13, 1991, during the review of job order 30087,
" Removal and Reinstallation of All Safety and EMRV Accelerometers and 1hermocouples per A100 "iE-3922.01.
It was determined that both of these job orders were made unnet.essarily complicated and made equivalent to a work procedure by the inclusion of prerequisites, precautions, limitations, and work sequences which were also in the preapproved work procedures referenced in the Job Order.
Instances were noted where information identical to the preapproved work procedures were co;ied into the Job Order contradicted information in the referenced preapproved procedure.
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GPUN Response to 1.d GPUN concurs with the violation as written.
The cause of this concern was that a procedure invoked by a Job Order contained generic precautions and prerequisites, separate from the specific precautions and prerequisites listed on the Job Order. Although this did create an unnecessary administrative concern for maintenance activities, it was not " unnecessarily complicated" No examples of this type of anomaly creating a plant concern have been identified.
However, GPUN does concur that the Job Order process could benefit by clarification of these items. The requisite section of the Instrumentation and Control Job Planning Guideline has been revised to more clearly define specific requirements, full compliance will be achieved when this information is presented to job planners in a briefing, presently scheduled fcr completion by June 30, 1991.
Violation 1.e Oyster Creek Station Procedure 105, " Control of Maintenance," Appendix C step 3.7
- states, "QA materials to be used must have been released for installation by QA and material traceability must be maintained until the material is installed."
Contrary to the above, on March 4,1991, multiple bags of QA material released for installation by QA was found stored at the intake electrical upgrade modification that did not have QA tags with them. The lack of QA tags made the material traceability impcssible.
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., ~... g OPUN Response to 1.e GPUN concurt with the violation as written, immediate corrective action was taken to establish traceability where possible, and return material to the warehouse for disposition. Two basic causes for this deficiency were identified: 1) the safety related portion (conduit supports) of a large non-safety related modification d d not receive adecuate attention: and
- 2) work practices by the job contractor ilid not comply wit 1 GPUN proceedures, field supervisors were instructed in ths use of GPUN procedures.
This was completed on April 11, 1991.
The generic deficiency of control of safety related materials in the field was addressed internally by a Quality Deficiency Report. A corrective action program was proposed and subsequently revised by appropriate maintenance personnel.
Full compliance was achieved with the completion of the Corrective Action Program as documented on May 3, 1991.
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