ML20082Q040
| ML20082Q040 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/09/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-91145, NUDOCS 9109110210 | |
| Download: ML20082Q040 (8) | |
Text
.
' New Hampshire Ted C. Feigenbaum h
Pruident and Chief tietutive Of ficer NYN 91145 September 9,1991 United States Nuclear Regulhtory Commission Washington, D.C.
20555 Al'ention:
Document Control Desk
References:
(a)
Facility Operating 1 icense No. NPF 86 Docket No. 50 44'l (b)
USNRC 1.c t ie r dated June 28, 1991, ' Inspection It e port No.
50 443/91 80*, M. W. Ilodges to T. C. Feigenbaum S ubject:
Response to inspretion Report Gentlemen:
NRC Inspection Report No. 50 443/9180 (Reference (b)) requested a response to the weaknesses listed on Page 98 of the Report. The New llampshire Yankee,has evaluated each of the weaknesses and our response is provided in the Enclosure.
Should you have any questions regarding this matter please contact Mr. James M.
Peubel, Regu;atory Compliance Manager, at (603) 474 9521, extension 3772.
Very truly yours, fggh 4 Ted C. Feige@aum Enclosure TCF:J M P/ss ce:
Mr. Thomas T. Martin Regional Adminirtrator U. S. Nuclear Regulator: Pommission Region i 475 Allendale Road King of h u6sia, PA 19406 t1 gg Mr. Gordon E. Edison, Sr, Project Manager gga Proj,ect Directorate 1-3 Division of Reactor Projects og So U.S. Nuclear Regulatory Commission Washington, DC 20555
~U Mr. Noel Dudley "4
NRC Senior Resident inspector 9 g 'n ~
P.O. Box 1149 0-3$
0 0 Seabrook, Nil 03874 00.0
'l' New Hampshire Yankee Division of Public Service Company of New Hampshire
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P.O. b 300
- Seabrook, NH 03874
- Telephone (603) 474 9521 l
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e of inspection Report _50 443/9180 listed four programmatic weaknesses, representing potential problems or conditions, for NilY evaluation and corrective action as appropriate. The N11Y response is provided below.
Item 1.
The process for updating maintenance procedures based on new or revised vendor information was not being donc in a timely manner.
No station requirement nisted to casure maintenance procedures were updated in a timely manner.
Hrsoonse:
The NitY process for the receipt, review and processing of vendor information is controlled by NilY Procedute 12410, ' Receipt, Processing and Approval of Vendor Documentation". The vendor information is reviewed by Engineering and entered in the NilY records management system, Upon completion of the Engineering reniew and the foreign printing process the vendor information is made available through controlled distribution.
Station procedure Shi 6.2, ' Station Operating procedures *, states in step 4.4.1.6 that *When a procedure is revised, referenced safety related vendor manuals shall be _ reviewed for any change since the last procedure review, if a controlled vendor manual has been revised, any pertinent changes shall be incorporated in the procedures which reference the vendor manual."
The Station is currently incorporating the vendor manual revisions as proceduret, are revised during the biennial procedure cycle.
Additionally, vendor technical information, such as vendor technical bulletins, is reviewed by the Operating Experience Review organization in accordance with N!!Y Procedure 12910, " Operating Experiencu Review Program". Vendor information that is significant and that merits prompt action is prioritired and action items are assigned to the appropriate department to ensure that the information is provided to the appropriate personnel and incorporated in procedures if required.
New ilampshire Yankee believes that the existing process ensurcri that the appropriate vendor information is prioritized and incorporated into procedures in a timely manner.
New Harnpshire Yankee will review the process for incorporation of vendor information, and any backlog, by December 1992 and make revisions to the process as appropriate.
Item 2.
The backlog of 1021 open engineering issues indicated an insufficient or inappropriate allocation of the existing engineering resources to support plant maintenance needs. Engineering control of the priority system for completion of Requests for Engineering Services was not timely for Priority 3 RESs.
Response
The back log of open engineering issues has been reduced from nearly 2400 at the beginning of 1990, to 729 as of August 30, 1991 as shown in Figure 1.
This planned reduction was accomplished through the close out of open issues to meet established goals.
An Engineering Status Report for the week ending January 25,1991 from the TAIL System, included in Inspection Report 9180, is included as Figure 2.
The January 25th report reflects an overall backlog of 1021 open engineering issues and a backlog of 665 RESs, The Aug-t 30,1991 version of this same 1
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report, provided 3s Pigure 3, reflects 729 open Enginecting issues and a backlog of 270 itESs. The reduction in open RESs is shown in Figure 4.
I On January 6,1991 there were 110 open, maintenance related Requests for Engineering Services (RE55) that had been prioritized by Maintenance. As of f
August 30, 1991 only 20 of these prioritired RES6 require attention by Engineering and one requires attention by Technical Support. Of the 89 RESr.
l that were closed, 77 were Priority 3.
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The Station provides directions to Engineering with regard to Design Coordination Reports (DCRs) and Minor Modifications (MMODs) by means
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of the Station Modification Resource Committee (SMRC). The SMRC, chaired by the Assistant Station Manager with the Engineering Manager ad Maintenance Manager as rnembers, assigns priorities to DCRs and MMODS.
With regard to maintenance related RESs, Maintenance provides direction to
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Engineering through the periodic review and prioritiration of open RESs.
l Engineering addresses these programmatic prioritizations along with other considerations such as the Station's day to day requirernents received at the l
daily Station Managers meeting or the Plan of the Day meeting as inputs to the l
overall prioritiration of engineering work. The reduction in the number of j
open engineering issues, including RESs, is due to increased management
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atterition to routine (Priority 3) work. The higher priority issues (Priority 1 and 2) are time bounded and receive prompt attention.
Engineering will i
continue its aggressive-program tu reduce open items and to ensure that maintenance issues are addressed in a timely manner consistent with overall Station requirements. The effectiveness of the RES priaritization process will be monitored and reviewed in 1992 to determine if process revisions are required.
i Item 3.
During the replacement of a time delay relay, electrical maintenance personnel l
did not completely implement s'ation proced ur e s.
Contrary to station l
procedure requirements, additional data was taken and not documented in the
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work package, nor was the supervisor notified that the procedure was not l
adequate for the task in that it did not require additional data to be taken to i
verify repeatability. Therefore, work documents did not allow an independent observer to determine what activities actually were performed. The origin and basis for these requirements were not documented and could not bc l
determined. The expectations of station management were not known to the maintenance supervisors or technicians.
Resnonse:
The Station Management Manual (SSMM) policy on Procedural Compliance was revised to explicitly state the types of additional tasks, not delineated in a procedure, that-may be performed in conjunction with the completion of the
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procedure. The revision also states that ' Additional tasks or data (defined as tasks or data not required by procedure) shall be documented in the i
appropriate work package."
l The Station Management Manual provides the policies governing the conduct of activities within the Station and clearly establishes the basis for the work package documentation requirements and communicates the policies and j
expectations to all personnel performing maintenance activities at the Station, j
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Item 4.
The control of tool and equipment storage was of significant concern due to undersired storage space, incomplete tool issue records, loss of tool accountability and tracking, and the use of improperly marked tools in the RCA.
Responso As stated in the inspection Report, NilY has initiated actions to improve the control of tools. These actions include both procedure revisions and changes to the physical storage locations for tools and equipment. The Maintenance organization has assumed control of the Chlorination Building and is now using that building as a clean machine shop and for the storage of specific tools and equipment.
The existing machine shop is now being utilized as the hot machine shop and for the storage of some tools and equipment. These actions allow the tool cribs to be utitired for the storage of those tools and that equipment that are used most frequently. Other tools and equipment can then be casily stored in the Chlorinatic-Huilding or the hot machine shop and obtained when needed.
Regarding procedural changes, Procedure MA 4.11, ' Tool Control' was revised to enhance the day to day control of tools rather than to utilire solely an annual tool crib inventory. The procedure now requires the ' required return i
date* for tools to bc Lept current and the Maintenance Department Supervisor i
to be informed if return date requirements are not met. The Maintenance Department Supervisor is also required to submit an annual report on missing and broken tools.
l The tools and equipment designatei 'or use within the RCA are painted f
magenta or are tagged with a mager.
tag. Procedure 4.11. " Tool Control *,
f now includes additional guidance addressing the issuance of tools for use within j
the Radiologically Controlled Area (RCA). The procedure states that " Tools and equipment needed to perform work within the RCA should be issued from the tool cribs located at the south end of the RCA walkway, or in the RCA Shop, or from satellite cribs established within the RCA during outages.
Authorization from the Maintenance Depa,tment Supervisor is required before
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non RCA maintenance tools and equipmen; may enter or leave the RCA. An inventory of non RCA maintenance tools and equipment entering or leaving the RCA will be provided to the Maintenance Department S u pe rvisor."
This procedure revision, along with the continued llealth Physics Department scrutiny of items entering the RCA, will minimize the number of non RCA tools entering the RCA.
L New llampshire Yardee will evaluate the tool control process at the end of
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the outage and-make the appropriate changes in existing procedures and l
i processes to institute positive tool control actions, j
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FIGURE 2 ENGINEERING STATUS REPORT FOR WEEK ENDING 01/25/91 TYPE DCR MMOD DRR RES TOTAL NEW ITEMS 0
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22 27 COMPLETED 2
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11 14 BACKLOG 263 61 32 665 1021 SCHEDULED 261 59 32 664 1016 UNSCHEDULED 2
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FIGURE 3 ENGINEERING STATUS REPORT FOR WEEK ENDING 08/30/91 TYPE DCR MMOD DRR RES TOTAL NEW ITEMS 7
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17' 48 BACKLOG 252 126 81 270 729 SCHEDULED 252 126 81 270 729 UNSCHEDULED.
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FIGURE 4 7__ _
- Er GINEERING RES BACKLOG REDUCTION-900 750 270 (08/30/91)
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1991 Goal = 250 l
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'90
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- 91
- 31 MONTH ' YEAR 2
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