ML20137E165
| ML20137E165 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/14/1985 |
| From: | Christensen H, Debs B, Moore L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137E140 | List: |
| References | |
| 50-369-85-32, 50-370-85-29, NUDOCS 8511270212 | |
| Download: ML20137E165 (10) | |
See also: IR 05000369/1985032
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.:
50-369/85-32 and 50-370/85-29
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Licensee:
Duke Power Company
422 South Church Street
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Charlotte, NC 28242
Docket Nos.:. 50-369 and 50-370
License Nos.:
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. Facility Name: McGuire 1 and 2
Inspection Conducted:
Se tember 23-27, 1985
Inspectors: .
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W. O. Christensen
Dafe Sifned
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'L.R.MooreQ
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ate Signed
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Approved by:
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B. T.' Debs, Acting Section Chief
Datd' Signed
Operational Programs Section
Division of Reactor Safety
SUMMARY
Scope:
This ' routine, unannounced inspection entailed 64 inspector-hours on site
in the area of maintenance programs,
Results:
One violation with five examples was identified
Violation
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50-370/85-29-01; Contrary to 10 CFR 50 Appendix B and Technical Specification , 6.8.1.a. the licensee:
a.
Failed to follow procedure when replacing a tubing test tee on a cold leg
accumulator level transmitter, 2NI LT 5110, which required Quality Control
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review.
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b.
Failed to retain calibration data sheets and independent verification
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checklist of cold leg accumulator level transmitters.
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c.
Failed to follow calibration procedure for cold leg accumulator level
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transmitters and initiate a procedure change when using unreviewed reference
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data ano calibration method for level instrument calibration.
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d.
Used an inadequate procedure to calibrate Unit 2 cold leg accumulators with
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Unit I reference data.
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DD11270212 851119
ADOCK 05000369
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Failed to conduct a required functional verification of cold leg
accumulators after completing maintenance.
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
- T. L. McConnell, Plant Manager
- A. F. Batts, Quality Assurance
- R. Branch, Quality Control Supervisor
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- S.'Capp, Planning Engineer
- J. A. Effinger, Quality Assurance
- E. E. Ester,. Project Services
- H. Farr, Instrument and Electrical Supervisor
- D. M. Franks, Quality Assurance
- R. A. Johanson, Performance
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- D. Marquis, Performance Engineer
- N. McCraw, Compliance
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- W. H. McDowell, Licensing, Corporate Office
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- S. McInnis, Compliance
- M. K. Nazar, Projects
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- D. Rains, Maintenance Superintendent
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- K. W. Recce, Instrument and Electrical Unit 1 Coordinator
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- M. Sample, Integrated Schedule
- D. E. Simmons, Instrument and Electrical Support Engineer
- G. Singletary, Instrument and Electrical Associate Engineer
- C. B. Taylor, Training / Safety
- J. W. Temple, Maintenance, Corporate Office
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- B. Travis, Operations
- L. E. Weaver, Station Services
- R. B. White, Instrument and Electrical Engineer
Other licensee employees contacted included engineers,
technicians,
operators, and mechanics.
NRC Resident Inspectors
- W. T. Orders, Senior Resident Inspector
- R. C. Pierson, Resident Inspector
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- H. C. Dance, Projects Section 2A Section Chief, Region II
- C
F. Smith, Reactor Inspector, Region II
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- M. A. Scott, Reactor Inspector, Region II
- Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized on September 27, 1985,
with those persons indicated in paragraph I above. The inspector described
the areas inspected and discussed in detail the inspection findings.
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dissenting comments were. received from the licensee. The licensee did not
identify as proprietary any of the materials provided to or reviewed by the
inspectors during this inspection.
3.
Corrective Maintenance (62700)
"
The inspectors reviewed the licensee's corrective maintenance program to
verify that the program had been established in accordance with regulatory
requirements, industry guides and standards, and Technical Specifications.
The review consisted of reviewing procedures, selected maintenance work
requests, and interviews with various maintenance personnel.
McGuire's
Station Directive 4.7, Control of the Maintenance Program, The Maintenance
Management Program Manual and Duke Power's Administration Policy Manual,
. sections 3.3 and 4.6,
establish the methods and responsibilities for
managing the initiation, planning, scheduling, execution, status tracking,
and documentation of maintenance work.
The inspectors noted the following:
McGuire's backlog of work request is approximately 3200 requests. Of
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this number, 450 require a plant outage to be worked.
The trend in
total number of work requests appear to be stable over the past year.
For September, the maintenance department was currently working 609
requests; approximately 1800 were in the planning or pending stage, 616
were new or just received, and 100 work requests were awaiting parts.
McGuire management and Duke corporate maintain a close track of the
work request status.
Corporate and upper plant management receive a
monthly status report on maintenance backlogs.
The maintenance
planning department receives a weekly computer printout, by planner, of
all work requests and their status from initiation to completion.
McGuire work request form is divided into nine sections.
Section I
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identifies the equipment to be worked on, the equipment problem, and
the job priority.Section II delineates the required pre-maintenance
requirements. These are safety considerat
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health physics involve-
ment, QC involvement, and the determinatior. if the equipment is safety-
related.
Section III of the work request is used by the planner to
determine work sequence and job requirements.
Section IV is used to
list the material used in the job, and Section V is used by the
maintenance crafts to document all maintenance actions taken with
respect to the job.
Section VI, if required, is used for health
physics concerns.
Section VII is used for the Quality Assurance
reviews, and Section VIII is used to indicate the func.tional
verification and its documentation. Also, it is the section, used to
specify any retest requirements.
Finally,Section IX is used for
documenting the work completion, acceptance, and approval of the
maintenance performed.
It was noted, in general, that in Section V of the work request, the
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crafts personnel were not documenting maintenance activities to the
detail necessary to provide effective feedback for management review or
equipment history evaluation. The individual areas of section V, which
are the equipment failure cause portion and the failure coding system
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portion used to maintain proper data for failure analysis and trend
forecasting, are not being utilized. A review of Section VIII, Retest
and/or Functional Verification section, indicated that for functional
verification tests, the methods section has not been very descriptive,
also the results are not documented in great detail. An example of
this is Work Request 121696 OPS, Investigative and Repair Leaking Line
on Upper Head Injection System.
The repair consisted of installing a
temporary modification which replaced a test pressure gage, removed a
leaking relief valve, used the internal relief valve of the pump in the
line, and replaced a fitting in the pipe to stop the leak.
The
functional test method stated, " observed location for installation and
did same." The results were documented " sat."
From this functional
test description and test results, it can not be determined what was
functionally
verified.
Maintenance
Management
Procedure
4.1,
Maintenance Activities Associated with the Functional Verification /
Surveillance Retest Program, gives guidance on the type of functional
verification required and how this verification should be documented.
Additionally, Station Directive
3.2.1,
Identi fying , Scheduling and
Performance of Plant Testing, establishes the program and responsi-
bilities for insuring components receive a functional verification or
retest following maintenance.
The procedure states that a functional
verification shall be performed on QA Conditions 1, 2,
3,
and 4
components, security systems, and Technical Specification related
components following maintenance and should be performed on other major
components of non-safety-related support systems. The inspector noted
that functional verification of non-safety-related equipment is usually
not required by the maintenance planners, as indicated by marking the
work request section II as "NO."
An example of where a functional test
should have been required was Work Request 123466 OPS to investigate
possibility of damage to IC condenser circulation water pump due to
receiving very high thrust bearing temperature alarms. The corrective
action was to replace oil in the upper and lower motor oil pots. Upon
completion of the oil change, no functional verification was performed
to determine if the oil change corrected the high thrust bearing
temperatures.
In reviewing numerous work requests, the inspector noted that Work Request 123686 OPS had several deficiencies. Work Request 123686 OPS
concerns the investigation and repair of cold leg accumulator level
loops. This work request required the instrument technicians to vent
all eight cold leg accumulator level transmitters and, if needed,
calibrate the transmitters to ensure the indicators in the control room
agree with the calibrated transmitters.
Additionally,
if the
technician was required to perform any instrument line tubing work, he
was required to contact Quality Control (QC). The maintenance planner
designated the work request as non-safety-related and quality control
review was not required. A designation of non-safety-related was based
on a review of the instrumentation manual, which classified the level
transmitter as being safety class for the impulse lines to the
instrument, but the instrument itself performed no safety-related
function. McGuire's quality standards manual for structures, systems,
and components defines safety-related as those structures, system <, and
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components which prevent or mitigate the consequences of postulated
accidents which could cause undue risk to the health and safety of the
public.
Additionally,
the quality standards manual
classifies
instrument piping connected to a QA Condition 1 (nuclear safety-
related) systems as QA Condition 1 components. However, the connected
instrument is not considered safety-related unless it performs a
necessary safety function.
10 CFR 50, Appendix B, Criterion V,
states; " Activities affecting
quality shall be prescribed by documented instructions, procedures, or
drawings, of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or
drawings.
Instructions,
procedures,
or drawings shall
include
appropriate quantitative or qualitative acceptance criteria for
determining that important activities have been satisfactorily
accomplished."
The approved Quality Assurance Program states, " Duke Power has
established and implemented a quality assurance program which conforms
to the criteria established in Appendix B to 10 CFR 50."
Section 17.2.5
of Duke's Quality Assurance Program states, "The basic, written
instructions and procedures for operation activities affecting quality
are contained in the Nuclear Production Department's, Administrative
Policy Manual for Nuclear Stations.
It is required that personnel
implement this manual as it pertains to the performance of their
activities."
Administrative Policy Manual, procedure (APM)
4.2,
Administrative
Instructions For Permanent Station Procedures, section 4.2.6, states,
'" Activities shall be conducted in accordance with the provisions of the
applicable procedure."
McGuire's Technical Specification 6.8.1.a, states; " Written procedures
shall
be established, implemented, and maintained covering the
activities of the applicable procedures recommended in Appendix A of
Regulatory Guide 1.33, Revision 2, February 1978."
Regulatory Guide 1.33, revision 2, February 1978, Appendix A, states,
that the following are typical safety-related activities that should be
covered by written procedures:
a.
Administrative Procedures on (a) procedure adherence and temporary
change method, (b) procedure review and approval, and (c) log
entries, record retention, and review procedures.
b.
Procedures for Performing Maintenance.
Maintenance that can
affect the performance of safety-related equipment should be
properly preplanned and performed in accordance with written
procedures, documented instructions, or drawings appropriate to
the circumstances.
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Wor'k Request 123686 OPS, had the following deficiencies:
The technician found a tubing test tee leak on cold leg
accumulator 'D'. level transmitter, 2NI LT 5110. The test tee was
replaced,-but quality control was not contacted as required by the
work instruction in section III of the work request.Section III,
stated, " Note: Any tubing work contact QC Prior!"
Accumulator Tank ievel drawing, MC-2499-N18.01, states that
fittings, tubings, and valves designated on' this detail by
classification (4s) of the fitting classification list are safety
class. Substitutes from other classifications are not permitted.
The tubing test tee is within the (4s) classification boundary.
Mechanical Instrumentation and Controls Instrument Standards,
drawing ICS-A-11, states that when a safety class' materials'
identification flag is shown at an instrument, the impulse line
between the isolation or manifold valve and the instrument is
excluded from ASME section III code requirements; however, the
appropriate safety class fittings and tubing shall be used.
The inspector contacted Quality Control (QC) instrument section
and an instrument QC inspector stated that the replaced test tee
should have received QC inspection and the inspection would have
consisted of a verification of proper material and a sight
inspection of the test tee replacement. The QC inspector also
stated that a non-conforming items report would be generated.
Additionally, Administrative Policy Manual
3.3,
Maintenance,
section 3.3.2.3(b) which states that for maintenance activity which
affects the pressure boundary of system or components classified
as ASME Boiler and Pressure Vessel code class 1, 2, or 3, a code
authorized inspector shall be provided an opportunity to review
the proposed activity prior to the beginning of work if required.
Contrary to the above, QC was not informed or provided an
opportunity to review the test tee replacement prior to repair as
required by the work request, section III. The inspector informed
the -licensee that this was an example of failure to follow
procedures (VIO 370/85-29-01). The licensee stated that the note
in section III of the work request pertained to entire tube
replacement work,'and not to a test tee fitting replacement.
Of the eight level transmitters - calibrated, only five of the
calibration data sheets were in the work package. A review of
section V of the work package indicates instrument 2NILT 5080 was
calibrated, but instruments 2NILT5100 and 2NILT5110 have no
documentation at all.
The inspector was informed by the
instrumentation supervisar that both instruments were calibrated.
Additionally, the independent verification checklist for level
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transmitters 2NILT 5060 and 2NILT 5070, which were calibrated on
April 24, 1985, was missing.
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Station Directive 2.1.1., Control of Master File Documents, states
in part, that document retention requirements are.six (6) years or
service life - whichever is greater for; copies of completed work
requests and equipment histories for measuring and test devices
- and installed process instrumentation.
Contrary to station directive 2.1.1, the licensee failed to retain
the calibration data sheets and an independent - verification
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checklist for work request 123686 OPS. The licensee was informed
that the .above was a second example of failure to follow
procedures.
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The calibration on April 24, 1985, of . cold leg accumulator
transmitters 2NILT 5060 and 2NILT 5070 were not performed as
specified by procedure, IP/0/A/3214/04, Calibration Procedure for
Rosemount Model 1152 Transmitters, step 10.1.7, which states,
" apply input pressures at approximately 0, 25, 50, 75 and 100% of
input range specified for this transmitter." .The only applied
input pressure to the transmitter was at input ranges of 0% and
100%. The licensee. informed the inspector that a different method
of ' calibration was performed on the instruments.
McGuire's-
- Station-Support Detachment, North, took a new elevation survey of
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the level transmitters as referenced to the cold leg accumulator
taps. - This- data was used by the instrumentation group to place
elevation reference marks on the wall next to the transmitters for
the 0% and 100% level reference. A tygon tube was. connected to the
level transmitter to act as the water column-pressure source. The
instrument technician then varied the height of the tube from the
0% reference point to the 100% reference point to calibrate the
transmitters' end points.
The inspector expressed concern over
this method of calibration because no approved procedure or
procedure change was initiated, and the reference data used by the
technician was not properly reviewed or approved for use.
Station Directive 4.2.1, Handling of. Station Procedures, states in-
. par',, that this directive applies to all, both safety-related and
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non-safety-related, station procedures with each being processed
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similarly except as noted.
If any deviation from the method and
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steps specified in procedures is necessary, a procedure change
shall be initiated. It is the responsibility of each person using
the procedure to ensure the procedure is followed or appropriate
procedure changes are initiated and approved prior to using the
procedures.
Contrary to Station Directive 4.2.1, the licensee failed to follow
IP/0/A/3214/04 or initiate an approved procedure change before
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using new unreviewed reference data. The licensee was informed
that the above.is the third example of a procedural violation.
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A review of Work Request 123686 OPS, section V, the maintenance
action taken, indicated that the technician performing the
calibrations of the transmitters discovered that the unit 2 cold
leg accumulator transmitters were calibrated with incorrect input
data from procedure IP/0/B/3000/03, revision 15, Accumulator Tank
Level
Calibration.
The
incorrect
input
data
was
used
February 1985 when performing the technical specification required
18 month calibration of the cold leg accumulator level trans-
mitters.
The inspector was concerned that the incorrect input
reference data could be approved in a procedure change and used,
and not be detected by the procedure review and approval process
or the review process associated with the completed work request.
Contrary to 10 CFR 50 Appendix B, Criterion V, the licensee
procedure IP/0/B/3000/03, revision 15, was inadequate in that the
licensee calibrated unit 2 cold leg accumulator level transmitters
with unit one reference data. The licensee was informed that this
is the fourth example of violation (370/85-29-01).
The inspector examined Work Request 123686 OPS, Investigate and
Repair Cold Leg Accumulator Level Loops, and Work Requests 023345PM
through 023352PM, Perform PM/PT on NI Accumulator Level Instruments.
The planner failed to require and the technician failed t) perform
functional verification of transmitters as required by Station
Directive 3.2.1, Identifying, Scheduling and Performance of Plant
Testing.
Station Directive
3.2.1,
states that a functional
verification shall be performed on QA Conditions 1, 2, 3, and 4,
security systems and Technical Specification related com?onents
following maintenance.
Cold leg accumulator instrumentat ion is
required by Technical Specification 3.5.1.1.e, which states that
each cold leg injection accumulator shall be operable with a
water level and pressure channel operable.
The licensee was informed that the failure to conduct cold leg
accumulator level transmitter functional verification is the fifth
example of failure to follow procedure.
(VIO 370/85-29-01).
With the exception of these examples of failure to follow procedures, the
corrective maintenance program, as implemented by McGuire station directives
and maintenance management procedures appear to be procedurally adequate in
meeting regulatory requirements, industry guides and standards and McGuire's
Technical Specifications.
4.
Preventive Maintenance Program (PM)
The inspector conducted a review of the licensee's implemented preventive
maintenance program (PM). This review consisted of reviewing the licensee's
administrative, quality, and maintenance department procedures and related
training and M&TE documentation required for maintenance accomplishment.
Included also were interviews of individuals responsible for planning,
scheduling, tracking, and developing PMs.
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Guidance for the McGuire Preventive' Maintenance- program is proiided by
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Maintenance Management Procedure 5.1 (Rev 1). PM scheduling is accomplished
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via this guidance by use of computer originated printouts displaying current
maintenance requirements on a biweekly basis.
The PM coordinator is
responsible for. proper distribution and tracking of maintenance tasks.
Review of the Management Information System (MIS) monthly data report for
August 1985 revealed a continued reduction in the backlog of outstanding PM
work re' quests indicative of successful PM scheduling implementation.
The inspector reviewed a number of vendor technical manuals for various
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plant components to determine the adequacy. of PM procedures to meet vendor
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suggested routine maintenance. Generic and specific procedures reviewed met
or exceeded vendor requirements. A lubrication and vibration toned analysis
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program has been established to monitor and analyze plant operating
equipment.
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Completed maintenance packages were reviewed to verify adequacy of training
and validity of test equipment utilized to perform mr.intenance. Except for
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two isolated cases, documentation of personnel t-aining was adequate.
Implementation of the Employee Training Qualification System (ETQS) program
by the licensee should eliminate such exceptions
in the future.
Additionally, qualification of maintenance and test equipment (M&TE) used to
perform maintenance tasks was verified.
M&TE selected from completed
maintenance was clearly traceable to national standards and properly
controlled.
Selected safety and Technical Specification related process
instrumentation was also verified to be controlled by an adequate
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calibration control program and traceable to national standards.
The PM Program, as implemented at McGuire, appears to be adequate in meeting
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the'.-requirements and commitments made in Technical
Specifications,
applicable regulatory guides and standards.
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