ML20136H143
| ML20136H143 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/03/1985 |
| From: | Briden D, Ramsett L TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML20136H086 | List: |
| References | |
| AD-1844.01, NUDOCS 8601090278 | |
| Download: ML20136H143 (52) | |
Text
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Davis-Besse Nuclear Power Station Unit No. 1 Administrative Procedure AD 18W.01 Preventive Maintenance IEfBWMRfla Record of Approval and Changes ,
Prepared by E. E. Burkhalter/B. R. Beyer/J. E. Orkins/R. A. Brown 1/15/76 Date Submitted by A / . /4 - 7 6 jssd Data Recommended by 8 /
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V ~ Station Superintendent Date l
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i AD 1844.01.15 TABLE OF CONTENTS P, ale List of Effective Pages ii 1.0 Purpose . . . . . . . . .... . ... . ....... 1 2.0 Scope . . . . . . . . . .. .. .. .. ........ 1 2.1 Applicability . . . .... . ... . ..... .. 1 2.2 Discussion . . . . .... .... .. .. .... 1 3.0 References . . . . . . . .... . .. .. . .. .... 2 4.0 Definitions . . . . . . ... . .... . . . ... .. 2 5.0 Responsibilities . . . . ..... ... .. .... .. 3 6.0 Procedure . . . . . . . .... . ... . ....... 4 6.1 Addition or Revision of PMS . . . . . ....... 4 6.2 PM Scheduling and Reporting . ... . . ...... 8 6.3 Rescheduling or Deletion of PMS . . ...... .. 9 6.4 Performance of PMS .... ...... .. .... 11 6.5 Trending of the PM Program . ... . . ...... 13 7.0 Flaures . . . . . . . . .... .... ..... ... 13 8.0 Records . . . . . . . . . ... . ... .. ...... 13 Attachments PM Activity Approval Form PM Deferral / Deletion Form PM Performer Checklist PM Feedback Sheet Tech Spec Equipment Operability Checkoff List
i! AD 1844.01.06 LIST OF EFFECTIVE PAGES Page Revision Page Revision i 6 13 6
_ 1 6 14 6 2 6 15 6 3 6 16 6 4 .6 17 6 5 6 18 6 6 6 19 6 7- 6 20 6 8 6 21 6 9 6 22 6
- 10 6 23 6 11- 6 24 6 12 6 s
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- N s y 1 AD 1844.01.06 I t
1.0 PURPOSE This procedure establishes administrative controls for the Davis-Besse Preventive Maintenance (PM) Program. .
2.0 SCOPE 2.1 Applicability 2.1.1 This procedure applies to preventive maintenance for all facilities, structures, systems, equipment and components affecting plant operation at the Davis-Besse Nuclear Power Station. '
2.1.2 This procedure applies to all personnel involved bitti the identification, performance, deferral, deletion, evaluation, review and approval of preventive mainte-nance activities at the Davis-Besse Nuclear Power
, Station. -
l 2.1.3 Equipment lubrication and calibration activities are generally excluded from this proceduta as these activities are controlled by other administrative procedures.
2.2 Discussion 2.2.1 It is the objective of the Toledo Edison Company to
- ensure that not only are the health and safety of the l public and environment adequately protected but also l that the financial investment of its stockholders is protected. The PM Program is intended to be a significant contributor to the accomplishment of these objectives.
2.2.2 It is the goal of Davis-Besse Nuclear Pow'er Station that 100% of all scheduled PMs shall be performed each month. Every effort shall be made to assure that PM l; activities are not allowed to become past due.
2.2.3 The Nuclose Mission Procedure DS-205,g" Plant Maintenance", establishes specific Mission organi-zation interfaces and responsibilities. In general, Nuclear Engineering Division personnel are responsible for identification and initial review of new PMs and revisions. In addition, this group will perform PM i program trending. Davis-Besse plant personnel are responsible for developing, implementing and 1 conducting the PM program in accordance with this procedure.
I 2.2.4 The requirements of this procedure shall be in effect a no later than January 31,1986.
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2 AD 1844.01.06
3.0 REFERENCES
3.1 AD 1805.00, " Procedure Preparation and Maintenance" 3.2 AD 1838.00, " Surveillance and Periodic Test Program" 3.3 AD 1839.00, " Station Operations" 3.4 AD 1844.00, " Conduct of Maintenance Activities" 3.5 AD 1844.02, " Control of Work (MWO)"
3.6 AD 1835.00, " Plant Cleanliness Inspection Program" 3.7 AD 1848.00, " Station Records and Documents Management" 3.8 TED Nuclear Quality Assurance Manual 3.9 NMP-DS-205, " Plant Maintenance" (later) 3.10 Davis-Besse Radiation Protection Manual 3.11 AD 1809.00, " Station Environmental Qualification Program" 4.0 DEFINITIONS 4.1 DBMMS (Davis-Besse Maintenance Management System) - A computer program utilized to control maintenance planning activities including generation of Preventive Maintenance Work Orders (PMWO). DBMMS contrins information for plant equipment, including that requ:. ring PM. Historical records and approved procedure references for performing PMs are also on DBHMS. (See DBletS Users Manual.)
4.2 Deferred PM - A PM whose performance has been delayed and rescheduled with the joint approval of the Assistant Plant Managers of Operations and Maintenance.
4.3 Environmental Qualification (EQ) - An evaluation of nuclear safety related equipment to ensure it is capable of performing
- its safety related function under environmental conditions associated with all normal, abnormal and accident plant conditions.
4.4 Fixed Anniversary (FA) PM - A PM which is to be performed on a fixed anniversary date regardless of when the PM was previously performed.
4.5 Fixed Interval (FI) PM - A PM which is to be performed at an interval determined by adding the PH frequency (in months) to the previous PMWO completion date.
t 4.6 Past Due PM - PMs shall be considered past due if they have exceeded 25% of the performance interval or if the condition or mode required for the performance of the PM has been entered and lef t without performance of the PM.
4.7 PM Specialist - A member of the Planning and Scheduling Department who is responsible for PM scheduling, initiation of PMWO's and updating 'dBittS for PMs.
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4.8 Preventive Maintenance - Those preplanned activities such as parts replacement, adjustment, tests and inspections which are intended to help assure the operability and prolong the service life of the affected component and reduce the frequency and/or impact of equipment failures.
4.9 Trending - A means offevaluating system performance / l availability in order to identify improvements to the PM Program and any needed equipment podifications.
5.0 RESPONSIBILITIES 5.1 Plant Mansaer 5.1.1 Assure that a preventive maintenance program is defined, developed and implemented at the Davis-Besse Nuclear Power Station.
5.2 Assistant Plant Manaaers - Operations and Maintenance 5.2.1 Provide for the overall management and conduct of the preventive maintenance program.
, 5.2.2 Review and concur with the preventive maintenance schedule.
5.2.3 Review and approve new preventive maintenance tasks.
5.2.4 Review and approve revisions to preventive maintenance tasks.
5.2.5 Review and approve any deferrals or deletions of preventive maintenance tasks.
5.3 Maintenance Department Lead Engineers 5.3.1 Review and recommend for approval any new PMs and I
revisions, deferrals, or deletions of any PMs.
5.4 Nuclear Systems Director 1
5.4.1 Appoint Responsible System Engineer cognizant of PMs on assigned systems.
5.4.2 Compile a summary report for PM Program trending which l
provides recommendations for PM Program improvement.
l 5.5 Responsible System Enaineers (RSE)
.5.5.1 Perform initial review of all new PMs and revisions, deferrals and deletions of any PMs.
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4 AD 1844.01.06 5.5.2 Monitor the PM schedules for assigned system (s) and assure that all scheduled PM activities are completed or that appropriate documented approval is given for deferral or deletion.
5.5.3 Perform trending on assigned system (s).
5.5.4 Identify new PM requirements associated with facility changes.
5.6 PM Specialist 5.6.1 Generate the PM schedule for each fuel cycle.
5.6.2 Issue quarterly updates to the schedule.
5.6.3 Issue monthly status reports. -
5.6.4 Update DBHMS PM files.
5.6.5 Generate PMW0s utilizing DBHMS.
5.6.6 Review completed PMW0s for PM Feedback Sheet input and other information provided by performer.
5.6.7 Track and expedite PM Deferral / Deletion Form requests.
6.0 PROCEDURE 6.1 Addition or Revision of PMs 6.1.1 Any Nuclear Mission personnel may initiate PM additions or revisions. The determination of the need for new PMs or additions to existing PMs should be based on:
A. Is the PM a part of a regulatory requirement such as environmental qualification, seismic qualification, or fire protection. Or does it impact personnel safety, vendor warranty requirements or ANI insurance requirements.
B. Would the failure of the component result in a reduction of the margin of safety.
C. Would the failure of the component result in a reduction of plant power generation capability.
D. Would the premature failure of the component Lupose significant financial loss to Toledo Edison.
.m 5 AD 1844.01.06 6.1.2 Criteria used to determine the need for preventive maintenance should include the following:
Regulatory requirements / guidance such as environ-mental qualification and Inspection and Enforce-ment Notices and Bulletins Industry experience such as Significant Operating Event Reports, Significant Event Reports, INPO,EPRI and NPRDS reports Davis-Besse operating experience Manufacturer's recommendations 6.1.3 The following should be considered as general guidance for selection of equipment for PM:
Parts replacement on non nuclear-safety related components with a dollar value of less than $500 should not be considered unless the failure of the component would result in any of the items covered in Section 6.1.1.
Infrequently used, manually actuated components which do not affect plant operation or safety should not receive periodic PM, but may require PM prior to use Components which have parts with a limited service life (less than 40 years) but whose failure would not impact plant operability or safety should not receive routine parts replace-ment (adequate spare and repair parts should be retained in the warehouse)
Where possible, pr dictive monitoring techniques (visual inspection for degradation, vibration analysis, oil analysis, thermography) shall be used in lieu of parts replacement Trending of equipment and system performance
! shall be used for input to the PM Program Responsibility Action Initiator 1. Completes a Preventive Maintenance Activity Approval (PMAA) Form (Attach-ment 1) when an addition or revision to o the PM Program is identified. See Attachment 1 for instructions for completing the PMAA Form. l
6 AD 1844.01.06 6.1.3 (continued)
Responsibility Action NOTE:
The basis for the PM should be determined as A, B, C, D defined in Section 6.1.1
- 2. Signs the " initiated by" block of the PMAA Form and forwards the form to the Responsible System Engineer.
Responsible System Engineer 3. Reviews the form to determine the following:
Is the request valid Does the request require a new PM or can an existing PM be enhanced Have all asscciated components been identified and evaluated for inclusion in the PM 1
Is the information on the form correct Is the equipment listed in the DBMMS database. If not, an equipment entry form must be completed and entered on the system prior to creating a new PM (AD 1044.02).
Responsible System Engineer 4. Assigns initial due date and (Continued) priority of the PM.
- 5. Signs tLe " submitted by" block of the PMAA Forn and forwards it to the appropriate Maintenance Discipline Lead Engineer.
Maintenance Lead Engineer 6. Reviews PMAA Form and identifies:
Additional rpare parts require-ments Associated PMs which should be performed with subject PM 4
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7 AD 1844.01.06 6.1.3 (continued)
Responsibility Action The need for any new or revised maintenance or other plant procedures Additional maintenance personnel training requirements
- 7. Determines disciplines and manhours required to perform the task.
- 8. Signs the " recommended by" block of the PMAA Form and forwards it to the Assistant Plant Manager - Operations.
Assistant Plant 9. Ensures that PMAA Form is reviewed by Manager - Operations Operations and thal a determination is made for the following :
Modes in which PM can be performed or can begin Effect of PM performance on Technical Specification equipment (completes Attachment 5)
Amplifying instructions for PM performer
- 10. Signs the PMAA Form and forwards to the Assistant Plant Manager - Maintenance.
Assistant Plant 11. Reviews the PMAA Form for correctness Manager - Maintenance and completeness.
Assistant Plant 12. Signs the form and forwards to the Manager - Maintenance Superintendent of Planning and l
(Continued) -
Scheduling.
PM Specialist 13. Completes the form by providing the following:
Related PMs Required procedures for perfor-mance
e 8 AD 1844.01.06 6.1.3 (continued)
Responsibility Action Post Maintenance Testing require-ments Q Class (including EQ)
Action summary Required permits Additional amplifying instructions
- 14. Enters required data for the PM into the DBMMS.
- 15. Signs the PMAA Form and forwards to
. Records Management for permanent retention.
6.2 PM Scheduling and Reporting 6.2.1 PM activities shall be scheduled using DBMMS. A PM schedule should contain equipment number, related PM numbers and a due date for each PM.
Responsibility Action PM Specialist 1. Generates PM schedule for upcoming fuel cycle at least 60 days before completion of fuel loading.
- 2. Routes schedule for approval to Assistant Plant Manager-Operations.
Assistant Plant 3. Reviews and signs schedule and for-Manager-Operations wards to Assistant Plant Manager-Main-tenance.
l Assistant Plant 4. Reviews and signs schedule and Manager-Maintenance returns to Superintendent of Planning and Scheduling.
j PM Specialist 5. Distributes schedule to Superinten-i dents / Supervisors with PM responsi-I bility and Nuclear Systems Manager.
l l 6. Updates and distributes a schedule for l
each quarter (at least one week prior l to each quarter) to reflect approved I changes.
l 9 AD 1844.01.06 6.2.1 (continued)
Responsibility Action
- 7. Provides monthly status reports at the end of each month to the Assistant Plant Managers for review and corrective action (as required).
The report shall list :
Backlogged PMs PMs past due by 3 times the frequency Reason for each PM that is backlogged or past due by 3 times the frequency
- 8. Provides monthly summary to Plant Manager which indicates the status of PM completion for the current month and a cumulative report for the fuel cycle.
- 9. Generates a Deviation Report (DVR) within one week if PM becomes significantly (three times frequency) past due. DVR shall indicate effect of nonperformance of the PM on component and system involved.
- 6.3 Reschedulina or Deletion of PMs 6.3.1 PMs shall be performed within 25% of the performance interval for fixed interval PMs or prior to exiting the required plant condition or mode for fixed anniversary PMs. Changes to required scheduling of a PM or deletion of a PM shall be made only by the joint, documented approval of the Assistant Plant Managers Operations and Maintenance. Anyone associated with the PM process may initiate a deferral or deletion request for a PM.
. Responsibility Action NOTE:
If at any time during the deferral or deletion review process it is determined that the PM cannot be deferred or deleted, the holder of the form shall notify the PM Specialist immediately to ensure timely (prior to being past due) performance of the PM.
I 10 AD 1844.01.06 6.3.1 (continued) l Responsibility Action '
1 Initiator 1. Prepares a PM Deferral / Deletion (PMDD) l Form (Attachment 2).
NOTE:
If PM is being deferred at the discretion of the Shift Supervisor, he/she shall prepare PMDD Form.
- 2. Submits PMDD Form to PM Specialist at least 10 working days prior to the subject PM becoming past due.
PM Specialist 3. Ensures that the form is dispositioned and approved prior to the PM becoming past due (tracks progress).
- 4. Signs PMDD form and forwards to Responsible System Engineer.
Responsible System Engineer 5. Determines if deferral / deletion is
.' justified and signs the " submitted by" block.
- 6. Forwards the PMDD form to the Mainte-nance Discipline Lead Engineer.
Maintenance 7. Reviews PMDD Form for impact on Lead Engineer maintenance procedures and training and spare parts retention. (This step may be performed after PMDD approval.).
NOTE:
Disagreements between initia-tor, PM Specialist, RSE and Maintenance Lead Engineer shall be brought to immediate attention of the Assistant Plant Managers for resolution.
- 8. Signs PMDD Form and forwards to Assis-tant Plant Manager-Operations.
Assistant Plant 9. Evaluates PMDD Form to assure that Manager-Operations deferral / deletion of PM will not adversely affect plant safety or l operability.
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11 AD 1844.01.06 6.3.1 (continued)
Responsibiltiy Action
- 10. Signs PMDD Form and forwards to Assis-tant Plant Manager-Maintenance.
Assistant Plant 11. Reviews the PMDD Form for complete-Manager-Maintenance ness and correctness.
- 12. Signs and forwards PMDD form to the Superintendent of Planning and Scheduling.
PM Specialist 13. Enters required data into DBHMS.
14.
Signs the PMAA Form and forwards it to Records Management for permanent retention.
6.4 Performance of PMc 6.4.1 Anyone may initiate revision, deletion, deferral or addition of PMs per the previously described sections.
PMWO generation is triggered by a schedule review by the PM Specialist.
Responsibility Action PM Specialist 1. Generates PMW0s prior to PM start date or prior to entry into required plant mode or condition for PM performance.
- 2. Initiates the individual PM packages (includes PM Performance Checklist and Feedback Sheet in the package).
NOTE:
I PMWO shall reference approved procedures to be used. (See AD 1844.00)
- 3. PMWO is processed per AD 1844.02, Control of Work (MWO).
Performer 4. Performs PMWO.
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12 AD 1844.01.06 6.4.1 (continued)
Responsibility Action
- 5. Performs the following additional actions:
Inspection for cleanliness and preservation Observation of physical deficiencies Observation of proper personnel safety devices Qualitative assessments (such as vibrational analysis and electrical or thermographic checks)
(Completes Attachment 3, PM Performer Checklist)
- 6. Initiates a Work Request when unsatisfactory conditions are observed.
NOTE:
Notify Shift Supervisor immediately, if the unsatisfactory condition affects operability or return to service of a plant system or component.
- 7. Completes PM Feedback Sheet (Attachment
- 4) when enhancement to PM is identified.
- 8. Completes PMWO and routes for closure l per AD 1844.02.
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- PM Specialist 9. Receives PMWO last.
- 10. Reviews the PM Feedback Sheet and forwards to Responsible System Engineer for disposition, if required.
- 11. Forwards PMWO to Data Entry Group (Planning and Scheduling).
Data Entry Group 12. Updates DBMMS to reflect PM completion.
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13 AD 1844.01.06 6.4.1 (continued)
Responsibility Action
- 13. Forwards PMWO to Records Management for permanent retention.
6.5 Trendina of the PM Program 6.5.1 Trending of equipment and system performance shall be used as input to the PM Program.
Responsibility Action Responsible System Engineer 1. Performs review for PM Program trends for each system at conclusion of each refueling cycle.
- 2. This review should include the following:
Observation of system / component performance degradation Component failures and root cause PMs which should be applied to other systems PMs which require frequency adjustment
- 3. Summarizes results by system and forwards to Nuclear Systems Manager.
Nuclear Systems Director 4. Combines reports for all systems and writes summary.
- 5. Provides report summary and recommenda-tions to Plant Manager and Senior Vice President, Nuclear.
- 6. Assigns appropriate Responsible System Engineer to disposition responses and comments to the report.
7.0 FIGURES None 8.0 RECORDS 8.1 The following documents shall be retained as permanent records:
The original, approved PM schedule for each fuel cycle
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14 AD 1844.01.06 8.1 (continued)
All approved PM Activity Approval Forms All approved PM Deferral / Deletion Forms All approved PMW0s.
PFEVENTIVE MAINTENANCE ACTIVITY APPROVAL FORM
- l. INITIAL ENTRY ((l OR REVISION ((j 2. P.M. NUMBER 3. BASIS
- 4. A/E EQUIP NUM: 15. EVENT CODE: NORM- NORMAL
- 5. RESP. AREA / DISCIPLINE (CIRCLE ONE) PRRFL PRE-REFUELING (BEFORE)
RFL ALL REFUELING OUTAGES
- 6. SUS NUMBER EVRFL EVEN REFUELING OUTAGES ODRFL ODD REFUELING OUTAGES
- 7. MODE REQUIRED: PORFL POST REFUELING (AFTER)
- 8. PM PRIORITY TGOUT TURBINE AND/OR GENERATOR OUTAGE
- 9. Q-CLASS CTNT CONTAINMENT ACCESS IS REQUIRED
- 11. INTERVAL: _ MONTHS ABOUT AUXILIARY BOILER OUTAGE
- 12. INITIAL DUE DATE: / / INACT INACTIVE (PM IS NOT IN USE)
- 13. ACTION SIR 9tARY: (25 Characters)
- 14. ACTION DESCRIPTION: (430 Characters)
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PREVENTIVE MAINTENANCE ACTIVITY APPROVAL FORM
- REQUIREMENTS *** *** SCHEDULING INFORMATION ESTIMATED ***
(Y OR N) HOURS CREW IG. PAINTING PERMIT: 17. WELDING:
CLEANLINESS INSP: MECHANICAL:
QC INSPECTION: ELECTRICAL:
TAGGING REQUIRED: PIPE:
REP REQUIRED: STATION SERV:
CONT SHEET ATT: I & C:
ENCLOSURE 13: OPERATIONS:
CONFINED SPACE: QC/ CODE INSP.:
C & HP:
STAFF:
SECURITY: PRIMARY DISCIPLINE OTHER:
- 18. RELATED PMS: -
- 19. REQUIRED PROCEDURES
- 20. POST. MAINT TEST:
- 21. AMPLIFYING INSTRUCTIONS: (140 Characters)
- 22. INITIATED BY: DATE:
- 23. SUBMITTED BY (RSE): DATE:
- 24. REC 0K,'NDED BY (MTCE LEAD EGR): DATE:
- 25. APPROVED BY (APM-0) DATE:
- 26. APPROVED BY (APM-M) DATE:
- 27. ENTERED INTO DBMMS (P & S) DATE:
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17 AD 1844.01.06 INSTRUCTIONS FOR COMPLETION OF PMAA FORM Description Responsibility Action Line 1 Initial Entry / Initiator Enter an "X" in the Revision box indicating whether the PM is new (initial entry) or a revision to an existing PM.
Line 2 PM Number Initiator Unique number which (Revision) identifies the Planning & specific PM activity.
Scheduling (P&S)
(New)
Line 3 Basis Initiator Basis code (A,B,C or D) for PM as described in Subsectio'n 6.1.1 of this procedure; Line 4 A/E Equip. Initiator Unique nurler which Number identifies the compon-ent affected, can be obtained from P&ID or directly from the component ID tag.
Line 5 Resp. Area / Initiator Group or maintenance Discipline discipline responsible (or performance of the Pd.
Line 6 SUS Number Initiator Startup System Number of the affected component.
Line 7 Mode Required APM-Ops The plant mode that is required for performance of the PM.
Line 8 PM Priority RSE Priority of the PM.
- 1. Regulatory requirement, impacts personnel safety or impacts equipment safety.
(Cannot 'be deferred unless required b
h Attachment 1 Page 3 of 6
i 18 AD 1844.01.06 e
Description Responsibility Action mode or condition cannot be established).
- 2. Important to power production. Incurs significant financ-ial cost if not performed.
- 3. Established as a result of perform-ance trending.
Nonperformance results in recurrence of known problem or equipment failure.
(Not 2 or 3 ites)
- 4. Established as a result of industry experience or manufacturer's recommendations.
(Not 1, 2 or 3 ites)
Line 9 Q Class P&S Component Quality classification (including EQ).
Line 10 PM Type Initiator Either fixed interval or fixed anniversary as described in Sections 4.2 and 4.3.
l Attachment 1 Page 4 of 6
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19 AD 1844.01.06 Description Responsibility Action l
Line 11 Interval Initiator Frequency for which the PM is to be performed.
Line 12 Initial Due Date RSE Initial date when PM is first performed.
Line 13 Action Summary P&S Brief summary of the action required by the PM. -
Line 14 Action Description Initiator / P & S Description of the PM to be performed.
Line 15 Event Code P&S Description of frequency of PM.
(Normal is PM not tied to plant event but performed at regular interval.)
Line 16 Required Permits P&S Identification of any permits required to perform the PM.
Line 17 Manhour Maintenance Estimate of the Estimate Lead Engineer / discipline machours PM Specialist and crew required to perform the PM.
Line 18 Related PMs P&S Any PMs to the same component, system or other components /
systems which are either affected or could be performed in conjunction with this PM.
Line 19 Required P&S Any procedures required Procedures to be used to perform the PM.
Line 20 Post-Maintenance P&S Identify any post-Test Required maintenance tests required subsequent to the performance of the PM.
Attachment 1 Page 5 of 6
e 20 AD 1844.01.06 -
l Description Responsibility Action Line 21 Amplifying P&S/ Any precautionary or Instructions APM-Ops other instruction which would clarify PM or aid in the perform-ance of the PM.
Lines 22 Signatures Self Explanatory through 27 Attachment 1 Page 6 of 6
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J 21 AD 1844.01.06 PREVENTIVE MAINTENANCE DEFERRAL / DELETION FORM Initiated by Date ,
(Print legibly) !
PM Number _3-Affected Equipment Description of task Q Class PM Type (Circle One) FA FI Description of Effect on Component and System Schedule for Performance (if applicable)
Justification for Deletion or Deferral (Circle One)
Enter Y or N Has this PM been previously performed ? Has this PM been previously deferred ? Is this PM the result of: manufacturer's recommendation
, environmental qualification , regulatory commitment ,
performance improvement recommendation ?
PM Specialist Date Submitted by Date Reviewed by Date Approved by APM,0 Date Approved by APM,M Date Entered into DBHMS Date Attachment 2 Page 1 of 1
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22 AD 1844.01.06 PM Performer Checklist
- 1. Perform Overall Visual Inspection As applicable, mark an X under column YES(Y) or N0(N). If YES, then circle appropriate item (s).
A. Cleanliness / Preservation Y N (Circle appropriate item (s))
Build up of dirt, grease,. oil, grime Rust or oxidation activity B. Physical Deficiencies Y N (Circle appropriate item (s))
Evidence of wear, deformation, cracked or broken components Degradation due to heat or chemical erosion Loose or ill-fitting parts Unusual, excessive vibration or noise Misalignment of parts or components Missing parts or components C. Proper Personnel Safety Devices Y N (Circle appropriate item (s))
Missing covers, shrouds or guards Missing or incorrectly sized hazard or warning signs
- 2. Qualitative Assessments If applicable, perform the following checks and mark with an X.
A. Vibrational analysis profile B. Electrical Checks Neggering Bridging Voltage measurements Current measurements Continuity Timing C. _ _ Thermographic Check Additional Comments:
1 Attachment 3 i Page 1 of 1 l
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f 23 AD 1844.01.06 MWO # 3- - -
RESP ENG:
PREVENTIVE MAINTENANCE FEEDBACK SEET COMPLETE THIS SEET IN ORDER TO UPDATE AND IMPROVE TE PM SYSTEM. LIST ALL INFORATION THAT WILL HELP TE NEXT PERSON DO THIS WORK.
REQUIRED TAGS:
PARTS NEED (STOCK #'S):
TOOLS NEEDED (SIZE, RANGE, RAGS, ETC.):
LOCATION (SPECIAL KEYS OR SECURITT NEEDS):
GENERAL COMMElrIS:
NAME: EXTENSION: _
RETURN FEEDBACK SHEET TO TR PM SPECIALIST.
I Attachment 4 i Page 1 of 1
24 AD 1844.01.06 TECH SPEC EQUIPMENT OPERABILITY CHECK 0FF LIST PM NO Sheet of PRE-MAINTENANCE
- 1. Equipment / System Rendered 4. Redundant Equipment Verified Inoperable Operable
- 2. Tech Spec Applicability (Modes) 5. Operators Notified 1/ 2/ 3/ 4/ 5/ 6/ S/S Date Tech. Spec. Refs.
- 3. Cog. Ind. Date 6. Shift Supervisor Approval S/S Date POST-MAINTENANCE
Responsible Individual:
- 8. Retest Requirements 9. Retest Completed Satisfactorily S/S Date
- 10. Operators Notified S/S Date Attachment 5 Page 1 of 1 END i
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QUESTION NO. 7A 7A. Provide a listing of MW0s on systems important to safety that will be outstanding at restart, and provide appropriate justifi-cation why completion before restart is not required.
RESPONSE TO QUESTION NO. 7A Haintenance Work Orders (MW0s) at Davis-Besse can be classed into two categories: 1. Those that must be completed prior to restart from the current outage and; 2. Those that do not have to be completed prior to restart.
All currently outstanding MW0s are receiving review by an Adhoc Subcommittee of the Independent Process Review Committee (IPRC) which reviews all output of the System Review and Test Program (SRTP).
This subcommittee utilized the following criteria for determining which MWO's will be required to be. completed prior to restart:
Required for restart (RR) from the System Review and Test Program (SRTP).
temp 2 c/56
Required per tue June 9 event Action Plans.
Required to ensure the operability of the systems reviewed by the SRTP.
Necessary to ensure containment integrity.
Necessary for safe operation of systems required for plant operation.
All MWO's which do not meet the above criteria fall into the category of "not required for restart." It is important to note that some MW0s in the 1-not required category will still receive strong consideration for comple-tion prior to restart but they will not be allowed to delay start-up.
The process outlined above results in dynamic lists of MWO's, and for this reason we feel that it is inappropriate to provide a list at this time.
Information contained on either list is available for review by the resident inspector upon request. If you have any further questions on these lists or the criteria utilized to generate them, please feel free to contact us to answer them.
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QUESTION NO. 7B 7B. Explain in more detail the criteria being used to determine MW0s to be completed prior to restart (Appendix III.2 p.e/24/11)
RESPONSE TO QUESTION NO. 7B The Planning Department is responsible for prioritization, scheduling, and tracking of all NWO's (whether preventive, corrective or modifications) and all work requests.
In addition to the methods used in our normal planning and scheduling effort, Toledo Edison committed, in the December 9,1985 NRC staff brief-ing to perform an independent review of all outstanding work items. This independent was completed by an Adhoc Subcommittee of the Independent Process Review Committee (IPRC), subject to evaluation and concurrence of the full IPRC. The criteria used in this independent review is detailed in the response to Question 7a.
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QUESTION NO. 7C 7C. Who is the operations department representative and who compris-es the Restart Committee, as it affects prioritization of MW0s?
(Appendix III.2 p. e/24/ll)
RESPONSE TO QUESTION NO. 7C The use of the title Operations Department Representative as referenced on page e/24/11 of Appendix III-2 needs clarification. An Operations Spe-cialist in the Planning Department is a former shift supervisor. The Operations Specialist is required to hold or have held a SRO license.
Additionally, there is an Operations Coordinator 4 representative from the Operations Department - (also a SRO), who assists the Operations Specialist in the prioritization of MW0s.
The. Restart Committee prioritizes MW0s relating to Facility Change Requests (FCRs) and Non-Conformance Reports (NCRs) for this outage. The Operations Specialist in the Planning Department, and the Operations Coordinator in the Operations Department are responsible for prioritizing all other Maintenance Work Orders (MW0s). A list of Restart Committee members is attached.
Additionally, for this restart, an Adhoc Subcommittee of the Independent Process Review Committee (IPRC) performed an additional review of all outstanding work items (as discussed in Question 7A).
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-Restart Committee Members
- B. Beyer Nuclear Projects Director
- C. T. Daft Quality Assurance Engineering Manager
- J. F. Helle Nuclear Facility Engineering Director
- D. A. Lee Outage Manager
- W. T. O'Connor Asst. Plant Manager, Operations
- R. F. Peters Nuclear Licensing Manager
- S. M. Quennoz Nuclear Engineering Group Manager temp 2 c/56
QUESTION NO. 7D 7D. Describe how you intend to close the backlog existing at restart considering the expected generation of additional MW0s following resumption of operations.
RESPONSE TO QUESTION NO. 7D Toledo Edison currently has in place a method for the prioritization of non-outage work activities. This methodology coupled with the outage i
criteria described in our response to Question No. 7A and the following management actions will be used to assure that any bs:klog existing at restart will be worked off in an expeditious manner.
Trending All open MWO's and WRs are trended on a weekly basis by the Planning and 1
Scheduling Department (P&SD). Overtime will be scheduled with craft
. personnel and supplemented with contractor personnel as appropriate to reduce the backlog of MWO's.
t Quarterly Reviews A quarterly review meeting to discuss MWO status and trends will be held with the Plant Manager, the Assistant Plant Managers for both Operations and Maintenance, and the Planning and Scheduling Superintendent. The quarterly review rseting is directed towards reducing the MWO backlog to levels acceptable to management and will recommend staff augmentation as appropriate.
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. Discussion of Industry Practices Toledo Edison management is committed to safe and reliable operation of Davis-Besse. Toledo Edison management is also committed towards reducing the number of outstanding NW0s at the tacility. Toledo Edison is concerned, however, that staff' reference of raw numbers of MW0s and comparison to raw i numbers at other facilities can be misleading. Toledo Edison has surveyed a number of other utility practices in this area. There are significant differences in the definitions, criteria, and accounting principles used from licensee to licensee.
For example, Toledo Edison typically issues one MWO for trouble shooting and a second MWO for repairs. Many of the licensees surveyed utilize a single MWO to cover both activities. ~Another example is minor repairs such as changing light bulbs, and cleanup activities. In this case, TED 4
issues MW0s to cover these activities while other utilities require work documentation (MW0s) only if there is fabrication involved. Toledo Edison alsa generates a single MWO for each instrument calibration. We under-stand other licensees utilize one MWO to cover multiple calibrations on a single system.
It appears-also that other licensees may report only those NW0s that relate to nuclear safety related (NSR) systems when responding to NRC questions concerning MW0s. Toledo Edison reports all MW0s.
f Other differences exist in documents used to authorize work. The only document at Davis-Besse that is used to authorize physical work is a MWO.
The utilities surveyed have a wide diversity of work authorization docu-temp 2 c/56
ments. Some utilities authorize work to be performed under NCRs, field change notices, or modifications documents similar to our FCRs. Some utilities in fact report only those activities that have safety significance.
Backlog It is also important to note wide variances in use of the term backlog.
At Toledo Edison, a MWO is considered backlogged for a variety of reasons.
For example, an MWO, whether preventive or corrective, is considered backlogged if it is waiting for parts, procedures, manpower, or plant conditions. All MW0s scheduled to be worked in future outages are good examples of MW0s backlogged waiting for plant conditions.
All Preventive Maintenance (PM) items at Davis-Besse are considered backlogged prior to entering the scheduled work window. PM items are scheduled with a given time frame in (work window) in which to perform the PM. Once a NWO is issued for a PM, even though the work window has not been entered, these MW0s are categorized backlogged.
Our survey indicated large variances in at work activities are consid-ered backlogged. Some utilities surveyed do not count any PMs as back-logged items whereas at Davis Besse all PMs are considered (and counted) as backlogged MW0s upon initiation of the MWO. Other licensees may report only those backlogged safety related items as backlogged MW0s.
The amount of backlogged MW0s at Davis-Besse pre 71ously reported to the Commission reflect the above accounting practices.
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The accounting and reporting practices in the area of Preventive Maintenance have been revised as a result nf a revision to AD 1844.01, " Preventive Maintenaace". The new accountieg practices implement a 125% late start date for preventive maintenance activities. Only those preventive maintenance
-activities which exceed the la.t= start date will be considered backlogged activities.
We invite the Commission and staff to review our methods and criteria and perform a follow-up site visit to gain a better understanding of this area.
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QUESTION NO. 8
- 8. In light of the fact that a formal training program for personnel performing maintenance on limitorque valve operations and personnel operating and analyzing data from MOVATS test equipment is listed as a post-startup item, how is it being assured that personnel perform-ing such actions prior to startup have received adequate training?
RESPONSE TO QUESTION NO. 8 All electric shop personnel performing Motor Operated Valve Analysis and Testing (MOVATS) related work have completed formal training on the equipment and methods from a MOVATS representative. Additionally, those personnel performing this work (with the exception of two individuals) have completed formal training on limitorque actuators conducted by the Toledo Edison Nuclear Training Division (NTD) or Babcock and Wilcox Co.
(B&W). The two individuals rentioned had the formal limitorque training waived based on previous experience. A summary of the MOVATS and Limitorque Training Program was presented to NRC staff in a meeting on December 16, 1985. A copy of this summary is attached.
'Since meeting with the staff on December 16, 1985, all engineering staff responsible for evaluating MOVATS test data have received training in this area. Documentation of both MOVATS and limitorque training is available for site inspection.
Additional Planned Action 3, page 14 of Findings, Corrective Actions and Generic Implications Report, Plan No. 12 commits to instituting a formal temp 2 c/56
A c training program for personnel performing Maintenance on Limitorque valve operators and personnel operating and analyzing d'ata from M0 VATS test equipment. This commitment appears as a post-startup item (LCTS No. 1258) that was reported in Appendix III-1 Post-startup Commitment Tracking Report. This item is intended to show that Toledo Edison's NTD will assume all responsibility for MOVATS related training activities after startup. Toledo Edison wishes to emphasize that all personnel performing MOVATS related activities have received formal documented training, as detailed above. After restart, the NTD will be responsible for providing both Limitorque Valve Actuator and M0 VATS training.
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TRAINING ON MOVATS -
Provided for:
o Electricians performing tests o QC inspectors monitoring work o Electrical maintenance staff for technical support of electricians Requirements for qualification of electricians performing tests:
o Previous limitorque actuator training or experience o 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of classroom / lab formal documented training using MOVATS test equipment o 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-the-job training which is documented by work history records Further training is planned for engineering staff reviewing MOVATS test data.
. Requalification of electricians is planned for once every two years.
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QUESTION NO. 9 l
Describe QA involvement with maintenance activities during the transition l to the new Maintenance Program.
RESPONSE TO QUESTION NO. 9 In conjunction with the improvements in the Maintenance Program, the Quality Assurance (QA) Program is also being restructured and strength-ened. The revised QA program under the direction of our new Director of '
. Quality Assurance, Mr. Lorren O. Ramsett will provide the inspection and verification functions necessary to ensure the improvements in the Maintenance Program are adequate, are in conformance with quality requirements, and are permanent. This restructuring and strengthening is in the following areas:
- Organization
- Quality Program
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- Procedure Review i - Engineering Review
- Operating Surveillance The restructuring is in process but has not been completed at this time.
4 Following however is a discussion of the improvements presently being i considered.in each of the areas identified above. The final organization will.be described in upcoming revision to the NQAM.
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ORGANIZATION ,
The Quality Assurance Organization is being strengthened by the addition of an Operations Quality Assurance Manager who will be responsable for directing inspections and surveillances to support day-to-day station activities. The Quality Assurance staff is also being increased from thirty (30) to fifty (51) personnel. Of these additions, eight are directly related to providing materials and quality control inspections to support maintenance activities.
QUALITY PROGRAM The Nuclear Quality Assurance Manual is being divided into two QA Pro-grams; one (Code) to describe compliance with the ASME Code, the other (Functional) to describe compliance with 10CFR50, Appendix B and Toledo Edison's committed NRC Regilatory Guides and ANSI Standards. This Func-tional manual is being formatted to describe the Quality Assurance con-trols which apply to the various functional areas such as Maintenance, Health Physics, and Operations. -Nuclear Mission Procedures to clearly establish responsibilities and interfaces necessary to support Station activities are also being established. The Nuclear Mission procedure effort is discussed in Section II.B.2 and Appendix B.2.1 of the C0A.
PROCEDURE REVIEW The responsibility for the Quality Assurance review of procedures is being separated into a dedicated procedure review group to remove this temp 2 c/56
collateral responsibility from the present audit group. This will permit
- the auditing group to concentrate on the conduct of audits. This proce-dure review is intended to verify that Quality Assurance Manual commit-ments and requirements have been satisfactorily addressed. In addition, the need for and establishment of Quality Control Hold / Witness Points is being accomplished during the review of new and revised Maintenance and Test Procedures.
ENGINEERING REVIEW The scope of the Quality Assurance Division is being expanded to include a Quality Engineering function. This function will provide a quality review of the engineering activities on a day-to-day basis, rather than relying on the audit function. Engineering documents to be reviewed by Quality Assurance prior to their release for use will include specifications, procurement documents, Facility Change Requests work packages, and the disposition of Nonconformance Reports. This review is intended to ensure tne adequacy of the engineering documents released to the Maintenance and Facility Modification Departments for implementation.
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OPERATING SURVEILLANCE A dedicated surveillance function is being established to supplement the formal Audit Program. This surveillance function will be responsible for observing the conduct of activities such as Maintenance, Modifications,
. Operations, Health Physics, and Material Control to verify procedures are
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available, being'followed, and that these activities are performed in a professional manner utilizing sound workmanship practices.
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. . - -. . . -. - - . - - . . . . - - . - . . . _ ~- . . .
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t RESPONSES TO QUESTIONS RELATING TO DAVIS-BESSE VALVES AF-599, AF-608 AND MS-106 t
AND OTHER SAFETY RELATED VALVES E
, (12 QUESTIONS)
. RECEIVED VIA TELECOPY DATED DECEMBER 13, 1985
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QUESTION NO. IA Identify all valve operating conditions and expected intervals for those that are known (i.e. test, normal, transients, limiting conditions).
RESPONSE TO QUESTION NO. lA
/ursuant to the requirements of 10 CFR Part 50 Appendix A - General Design Criteria for Nuclear Power Plants, the principal design criteria that establish the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components to provide reasonable assurance that the facility can be operated without undue risk to the healta and safety of the public has been provided in the Davis-Besse Final Safety Analysis Report (FSAR). This criteria has previously been reviewed by the Commission and determined acceptable.
The principal design criteria for the Davis-Besse Nuclear Power Station No. 1 included consideration of the need to design against single failures of passive components, consideration of redundancy and diversity require-ments, consideration of the type, size, and orientation of possible breaks i
in reactor coolant pressure boundary components in determining suitable protection against postulated loss-of-coolant accidents, and consideration of the possibility of systematic, nonrandom, concurrent failures of redundant elements in the design of protection and reactivity control systems.
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Safety related valves are designed to operate under all conditions associ-ated with the principal design criteria for the system in which the valve is designed to function. Normal and abnormal operations of the various systems and components and the susceptibility of individual components to malfunction or failure are discussed in various sections of the FSAR.
Section 15 - Accident Analysis of the FSAR further explores the consequences of abnormal situations or failures given the three classes of accidents.
Class 3 - Design Basis Accidents are accidents of very low probability, but are postulated because the conservatively calculated potential offsite doses resulting from these accidents are significant. The analysis of all classes of accidents concluded the facility could be operated without undue risk to the health and safety of the public.
Specification documents detail the maximum design conditions for each safety related valve at Davis-Besse, as derived from the design basis.
Toledo Edison is verifying that all safety related motor operated valves will function under conditions specified in the design bases. This veri-fication is being performed utilizing the Motor Operated Valve Analysis and Testing System (MOVATS) technology, delta P testing of selected valve / operator installations and engineering review of data from manufacturers and prior testing.
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QUESTION NO. IB Is the use of a single open and a single close torque switch setting in each direction of valve travel adequate for all conditions?
RESPONSE TO QUESTION 1B Independent of the fact that a torque switch can only have one setting in each direction, a single open and a single close torque switch setting is adequate for protection of tne operator and the valve. Torque switch settings are made in accordeace with manufacturer's recommended values.
Manufacturer's recommended values are based upon the specifics of the actuator and its individual application to service. The torque switch settings recommended by the manufacturer take into consideration all valve operating conditions specified in the design basis for the system in which
-the valve actuator assembly is to functio 9. These settings are calculated to prevent damage to the valve and the motor operator.
The manufacturer recommends four different settings for torque switches.
These are:
normal recommended setting for the open direction maximum recommended setting for the open direction normal recommended setting for the closed direction maximum recommended setting for the closed direction mj a/48
Toleo Edison utilizes the manufacturer's normal recommended settings for 4 i
the open and closed direction for all valves with the exception of wedge seating safety related valves. Toledo Edison uses the manufacturer's normal recommended setting for the closed direction and the manufacturer's maximum recommended setting for the open direction for all safety related wedge seating valves. The maximum recommended setting is used in the
.open direction to provide added confidence that the valve will open when required.
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QUESTION NO. 2A Specify the max delta P that was experienced by AF599 and 608 during the event.
RESPONSE TO QUESTION NO. 2A Toledo Edison has conservatively estimated the maximum delta P experienced by AF599 and 608 during the event to be 1500 psid. This delta P is based upon an auxiliary feedpump turbine (AFPT) overspeed trip. This overspeed trip could have resulted in an instantaneous pump discharge pressure of 2400 psig upstream of the valves. This pressure (coupled with the 900 psig operating pressure of the steam generator seen downstream of the AF599 and 608 valves at the time of the overspeed trip) results in a maximum postulated delta P of 1500 psid.
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6-QUESTION NO. 2B Will'it be expected that delta P's'in excess of 1050 psid will be experi-enced in the future? If not, why not?
RESPONSE TO QUESTION NO. 2B As a result of lessons learned from the June 9, 1985 event, Toledo Edison is implementing several modifications to the Steam Feedwater Rupture
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. Control System (SFRCS) and the Auxiliary Feedwater (AFW) System which will act to'precluda delta Ps in excess of 1050 psid across AF599 and AF608.
The most important change is the installation of steam admission valves in the Auxiliary Feedpump (AFP) Turbine Steam Inlet Lines. These valves allow the steam inlet lines to be kept hot and pressurized to within 10 feet of the turbines. This situation will eliminate the cause of the June 9, 1985 turbine overspeed and provides assurance that AFP discharge pressure will not exceed 1180 psig which when coupled with st'am e generator pressure results in less than 1050 psid delta P. Another important modification is the logic change to the SFRCS that prevents closure of the associated valve (AF599 or AF608) on the last steam generator to depressurize below 600 psig.
This change assures that, even with a postulated single failure, Auxiliary Feedwater will be available to feed at least one steam generator.
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. Additionally, the SFRCS Manual Initiation Switches in the Control Room have been re-arranged to minimize the possibility of inadvertantly causing both AF599 and AF608 to go closed. This re-arrangement is further enhanced by the addition of clear plastic cover plates over the "SG Low Pressure Trip" switches.
All of the above modifications and procedural improvements combine to provide assurance that AF599 and/or AF608 will not be subjected to differen-tial pressure in excess of 1050 psid.
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QUESTION NO. 3 Explain in detail the methodology used to set A. Bypass limit switches B. Torque switches C. Limit switches for both directions of valve travel.
RESPONSE TO QUESTION NO. 3 The methodology of setting (adjusting) both the torque switches and limit switches are detailed in the following maintenance procedures.
MP 1410.32 Testing of Motor Operated Valves Using MOVATS.
MP 1411.04 Maintenance and Repair of Limitorque Valve Operators Type SMB-000 and SMB-03.
MP 1411.05 Maintenance and Repair of Limitorque Valve Operators Type SMB-0 through SMB-4 MP 1411.07 Maintenance and Repair of Limitorque Valve Operator Type SMC-04 Copies of these procedures are enclosed.
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