ML20137N791
ML20137N791 | |
Person / Time | |
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Site: | Saint Lucie |
Issue date: | 06/28/1996 |
From: | FLORIDA POWER & LIGHT CO. |
To: | |
Shared Package | |
ML20137K821 | List:
|
References | |
FOIA-96-485 NUDOCS 9704090057 | |
Download: ML20137N791 (100) | |
Text
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l SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE 5FFECTIVENESS OF MAINTENANCE ON STRUCTURES ST. LUCIE UNITS 1 AND 2 l
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES i
Table of Contents Page No, introduction 3
l Purpose 3
f Scope Basis for Determination 4
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Structure identification 5-6 Risk Significance 7
l Performance Criteria 7-8 Initial Assessment of Performance 8-9 j
Existing Plant Programs 10 Results 11 j
Recommendations 11 References 12 i
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Attachments No. of Pages 1
Review of Plant Historical Data 8
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Scoping of Structures 3
3 Review of Existing Programs 2
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SCOPE.WPD
SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES Introduction The implementation of the Maintenance Rule requires monitoring of the effectiveness of maintenance activities on structures as well as on systems and components.
Structures are different from systems and components in that they perform their funcbons in a passive manner. They tend to have long service lives and age relatively slowly. Performance monitoring typically used for systems and components which rely on active indication such as flow or change of state are generally not applicable or sufficient for structures. Condition monitoring is generally more effective means of monitoring the performance of structures.
A structure which is damaged or degraded to the point to where they can no longer perform their structural functions should be classified as a functional failure in accordance with the Maintenance Rule. Because of the safety factors included in the design of structures at St. Lucie Nuclear Power Plant, Units 1 and 2, (PSL), it would take extreme environmental conditions or years of neglect for a functional failure of a structure to occur.
Several monitoring and assessment programs are already in place at PSL which collectively address potential and actual degradation. The existing monitoring programs will be incorporated into a systematic structural monitoring program, which will consist of procedures that describe the importance of these existing programs to the assurance of structural performance, and establishes responsibilities and requirements for monitoring, reviewing, and evaluating the performance of structures at PSL.
Purpose The purpose of this document is to identify the bases and scope for the structures included in the structural monitoring program at St. Lucie Nuclear Power Plant, Units 1 and 2, (PSL), as required under the 10 CFR 50.65 - Maintenance Rule.
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES Scope / Bases for Determination The scope of structures that are part of the PSL structural monitoring program shall l
include all safety related structures and in addition any non-safety related structures that are:
i 1.
Relied upon to mitigate the accidents or transients 2.
Are used in Emergency Operating Procedures (EOP's) 4 3.
Whose failure could prevent safety related SSC's from fulfilling their intended function.
4.
Whose failure could cause a scram or actuation of a safety related system.
5.
That are relied upon for :.
a)
Fire Protection (10 CFR 50.48) b)
Environmental Qualification (10 CFR 50.49) c)
Pressurized Thermal Shock (10 CFR 50.61) d)
Anticipated transients without scram (10 CFR 50.62) 6.
Additionally, the methodology in this program may be applied, in a non-regulatory application to structures outside of the scope of the rule due to a favorable, cost-benefit analysis that justifies inspections to ensure continued performance of the structure, to increase availability of the plant, or minimize repair costs.
Included within the scope of structures, besides the structural supporting elements such as walls, floors, roofs, and related structural members are the following items which are located within or on top of structures that are part of the Maintenance Rule:
1.
The structural portion of cranes (i.e. bridge, rails, anchorage, etc).
2.
Platforms located within safety related structures.
3.
Missile! Radiation shields.
4.
Embedded structural members such as plates angles, and channels.
5.
Steel cavity liners such as fuel pool and reactor cavity.
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MA'lNTENANCE ON STRUCTURES Structure identification All structures at PSL were reviewed for applicability to the scope identified above and categorized based on their required functions.
1.
Applicability to scope l
Determination for application of scope was based on following considerations and expert panel discussion.
1.
UFSAR requirements and classifications 2.
Trichnical Specifications requirements 3.
EOP requirements 4.
Key structural components of the structure 5.
Probability Risk / Safety Analysis requirements 6.
Commercial Considerations 2.
Function The structures included in the PSL Structural Monitoring Program can be divided into five groups based on their primary functions.
Group 1 Structures that resist and/or retain pressures due to gaseous radioactive release. (Control the release of radioactivity)
Group 2 Structure that provide support and protection for safety related equipment.
Group 3 Structures that provide for the ability to maintain the environment required for safe and reliable operation, such as serving as radiation shields or missile shields Group 4 Structures that retain fluids.
l Group 5 Miscellaneous Structures (ll/l or commercial considerations)
Note: Reference 5, gives additional discussion and description of the basis for the five functional groups. Also discussed is experience data from other Nuclear plants associated with each group.
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES Structure Identification (continued) i 3.
Structures included in PSL Monitoring Program The structures which are part of the PSL monitoring program and their primary function as identified above are listed below Reactor Building Shield building (Group 3) i Containment Vessel (Group 1)
Interior Structure (Group 2)
Reactor Auxiliary Building (Group 2) l Fuel Handling Building (Group 2) l Steam Trestle (Group 2)
Diesel Generator Building (Group 2)
Intake Structure (Group 2)
Component Cooling Water Heat Exchanger and Pump Area
- including pipe trenches (Unit 1) (Group 2)
Component Cooling Area Structure, including pipe trenches (Unit 2) (Group 2)
Ultimate Heat Sink Dam (Group 4)
Refueling Water Tank & Foundation (Group 4)
Condensate Storage Tank (Group 4)
Condensate Storage Tank Shielding (Group 3)
Diesel Oil Storage Tank (Group 4)
Diesel Oil Storage Tank Pumphouses (Group 3) l Turbine Building (Group 5) l Flood Protection Stop Logs (South side of Unit 2 RAB and southem most door on east wall)(Group 5)
Main Transformer Barrier Walls & Foundations (Group 5)
Sta'rt-Up Transformers Barrier Walls & Foundations (Group 5)
Auxiliary Transformers Foundations (Group 5)
Cooling Canals (Group 5) intake Head Wall (Group 5) intake Pipe Line (Group 5)
Intake Velocity Cap (Group 5)
Seal Well Structure (Group 5)
Discharge Head Wall (Group 5)
Discharge Piping (Group 5)
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES j
Risk Significance l
l Risk significance for the structures identified as part of this program were established i
based on review of PSL Probability Risk / Safety Analysis, and critical safety functions system performance review. Additionally Group 1 structures were considered to be the most risk significant, based on their function to contain pressures essentially by serving j
as a leak tight barrier under postulated accident conditions and extreme environmental loads. Based on this review the following structures were identified as being risk significant.
J 1.
Reactor Building - Shield Building / Containment Vessel / Interior Structure l
The Reactor Building represents the third and final barrier between the fission i
products in the fuel and the environment. This is accomplished in part by having a negative differential pressure between the containment vessel and the shield l
building annulus. The Reactor Building is safety related structure which is relied l
upon to remain functional during and following design basis events to ensure the capability to mitigate the consequences of accidents that could resuit in potential offsite exposure comparable to the 10 CFR part 100 guidelines. This structure is risk significant per the PSA.
2.
Refueling Water Tank 3
Condensate Storage Tank 4.
Diesel Oil Storage Tank All of the tanks included in this program were modeled in the PSA and are risk significant.
Performance Criteria 1.
Specific Criteria A.
Reactor Building 1.
Surveillance and testing criteria as identified in Technical Specification Sunteillance Requirements. (Reference sections 4.6.1.6, 4.6.4.2.b.2, 4.6.6.2, 4.6.6.3) Although an indication of structural degradation, leakrate testing / surveillance and performance is monitored and tracked within the scope of Containment Penetrations, system 68.
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2.
No Maintenance Preventable Functional Failures 7
SCOPE. WPD
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MO'NITORING THE
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EFFECTIVENESS OF MAINTENANCE ON STRUCTURES B.
Refueling Water Tank Condensate Storage Tank l
Diesel Oil Storage Tank j
1.
No Maintenance Preventable Functional Failures, 2.
Tank shall be surveyed for signs of degradation as part of the Plant Level Performance Criteria.
2.
Plant Level Performance Criteria for ALL Structures in Program A.
No Maintenance Preventable Functional Failures.
B.
All structures will perform their required functions throughout their service l
i lives without impairment by degradation effects. Criteria for identification of degradation effects for baseline and periodic surveys are contained in ADM-17.08 and for general monitoring are contained in SCE-03.
C.
No structure shall fail in such a way which would cause a reactor scram or excessive unplanned unit availability.
Initial Assessment of Structures Performance 1.
Review of Historical Plant Data A review of historical plant data from July 1,1993, for approximately a three year period prior to the implementation date for the rule, has been performed to determine whether or not the subject structures have had acceptable performance based on the above performance criteria. Historical plant data that was' reviewed included but was not limited to Condition Reports (CR), Plant Change Modifications (PCM), Non -Conformance Reports (NCR), St, Lucie Action Requests (STAR), and Plant Work Orders (PWO). Based on this review, attachment 1 to this document describes specific documents used for assessing the condition of the structures in more detail.
2.
Baseline Survey of the Condition of the Plant An initial walkdown shall be performed to determine the condition of the plant structures. This walkdown shallinclude:
description and location of any identified degradation photos, sketches, to identify the as-found condition of the degradation.
photos, sketches of newly repaired areas to be used to gage effectiveness of the repair methods over time.
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE l
MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES 3.
Periodic Surveys of the Condition of the Plant l
Based on the results of the initial baseline survey of the condition of the plant, periodic condition surveys of the plant will be conducted to update the baseline survey, and to identify any trends in the condition of the structures. The periodic condition surveys shall be performed at intervals not to exceed five years.
NUREG and NEl (references 4 and 3) guidelines recommend that the periodic surveys be conducted within a range of every five to ten years. A maximum five year interval, which is on the low end of the range, was chosen for PSL primarily I
due to the salt environment that exists around the plant. The interval may be shortened if it is deemed necessary, based on information such as the structural condition assessments, on-going general monitoring activities, unusual events, or industrywide operating experience.
4.
Review of Industry Operating Experience Monitoring of plant and industry experience provides the principal discovery means for unknown and theorized causes of structural degradations. The materials used for construction at PSL are common to nuclear plants and to many non-nuclear power plants and have long operating histories. Monitoring plant and industry experience provides timely information related to potential degradations that can give reasonable assurances that similar degradations could be identified before they severely affect the functions of structures at PSL.
Industry information is distributed via the Institute of Nuclear Power Operation's Significant Event Evaluation Information Network program. Examples of information that is contained in the program are:
Part 21 Notices NRC Bulletins NRC Information Notices NRC Generic Letters Vendor Information Letters Operating Experience Information Significant Event Reports Operations and Maintenance Reminders Significant Operating Experience Reports A review of this program has been conducted, the specific results of this review l
is contained in attachment 1. Based on this review no messages where considered applicable or identified unexpected degradation effects for structures at PSL.-
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES Existing Plant Programs Used for Ongoing Condition Monitoring Existing plant programs are often the most direct and systematic method of detecting and preventing structure degradation. They already exist to meet regulatory requirements or recommendations, warranty requirements, or for economic considerations.
A review of existing plant programs was performed to determine which programs may be useful for ongoing condition monitoring of structures. A list of the identified programs is contained in attachment 3. These existing programs have been divided into the following groups -
General Monitoring Requirements Power Block Structure Monitpring Land Utilization Structure Specific inspections & Tests System specNic inspections and surveillances Structural Walkdowns for plant modifications Based on this review most of the existing programs are adequate, as they currently exist, to identify and detect potential areas of structure degradation. These programs are used to supplement the baseline and periodic condition surveys. The following procedures shall be revised to identify and clarify the responsibilities for the general monitoring requirements for surveying the condition of structures as part of plant personnel's daily work activities.
AP 000750 Duties and Respons:bilities of the System Engineer ADM-08.02 Conduct of Maintenance 0-01-99-02 Watchstation General inspection Instructions in order to provide guidance to plant personnel performing condition surveys of structures, a new guideline shall be issued (Reference Guideline SCE-03), which shall provide general criteria to assist in identifying potential areas of degradation.
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES Results assessment of degradation:
Base:t on review of the historical and industry wide data all structures that are part of the program are considered acceptable.
The historical plant data did not identify conditions which appear to be repetitive in nature or indicate any adverse trends in the performance of the structures.
Condition Survev Results.
The baseline condition survey shall be scheduled and the results documented via the Plant Management Action item Corrective Action Tracking Program, Procedure No. AP 0006129.
Information relative to the changes in condition or the continued degradation since orevious examination of the areas will be addressed in the quarterly assements based on monitoring corrective actions and periodic updates of the baseline survey.
Conclusions on the ability of the structures to oerform their intended function:
Based on the acceptable condition of the structures, and application of the specific and plant level performance criteria all are capable of performing their intended functions as identified in this scoping document.
Recommendations l
l Recommendations for additional investigation, corrective actions, or future examination where appropriate.
1.
Based on the environmental conditions associated with the intake Structure, the on going repair that was partially implemented during the current refueling outage (April 1996) as part of the disposition for STAR 1-950606 should be monitored at least once every 12 months for accelerated signs of degradation.
This item will be incorporated in to our schedule for baseline and periodic walkdowns, which shall be made part of a documented and retrievable plant process such as the PMAI Corrective Action Tracking Program.
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SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE.FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES References 1.
10 CFR 50.65 The Maintenance Rule 2.
NUREG 1526 " Lessons Learned From Early implementation of the Maintenance Rule at Nine Nuclear Power Plants" June 1995.
3.
NEl 96-03, " Guideline for Monitoring the Condition of Structures at Nuclear Power Plants", Rev. C, March 14,1996.
4.
NUREG 1522 " Assessment of Inservice Conditions of Safety-Related Nuclear Plant Structures" 5.
Ashar, H., Jeng, D., " Regulatory Perspective on Performance of Structures-Current issues Related to Nuclear Power Plant Structures, Equipment and Piping", Orlando, FL., December 1994.
6.
ADM-17.08, implementation of 10 CFR 50.65 The Maintenance Rule 12 scorr.aro
i ATTACHMENT 1 to the Scoping Document for the implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures i
Review of Plant Historical Data (July 1993 up to July 1996) 1 Condition Reports (CR). Action ReauestsfSTAR). and Non-Conformance Beoorts(NCR)
Reactor Containment Building CR 96-512 (April 12,1996) s The shaft seal for the outer door's handwheel on the outer containment Personnel Hatch tailed during the semi-annual strong back test. Due to LCO time constraints, a j
temporary blind flange was installed on the door operator shaft opening as allowed by Engineering Safety Evaluation. The shaft seal assembly was reinstalled at a later date s
to restore the field condition in accordance with design documentation.
The root cause evaluation associated with this CR identified a number of PWO's identified with the exterior door's exterior handwheel for this personnel airlock. This review suggests a specific localized problem associated with this handwheel.
Specifically the evaluation suggested that the problems associated with this handwheel is due to local drive shaft misalignment. As part of the CR's final disposition on 4/20/96 Engineering recommended that the handwheel assembly be disassembled and the drive components be inspected for misalignment.
STAR's 950587 (May 31,1995) and 950588 (May 31,1995)
These STAR's were issued to document the response to NRC Generic Letter 92-01, Revision 1, Supplement 1: Reactor Vessel Structural Integrity. The response to the GL consisted of Engineering Evaluation JPN-PSL-SESP-95-097, and Letter L-95-232.
Reactor Auxiliary Building STAR 1-94110396 (November 8,1994)
This STAR identified a spalled area at the top of a masonry block wall. This wall was determined to be a non load bearing, non-fire barrier wall. Based on field walkdown the spalled area was not due to degradation, but was probably caused when the area was removed to allow installation of a support, which is located directly above the area. Due to the location, extent of the non-conforming area the function or structuralintegrity of the wall was not affected and repair of the subject area was not required.
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ATTACHMENT 1 to the Scoping Document for the implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures STAR 960377 (March 4,1996) i This STAR identified corrosion at Non-safety related RAB air intake hoods and l
embedded angles around the opening in the RAB concrete wall. Some minor concrete repair was performed around the embedded angles, the existing structure repaired and all surfaces metalized in accordance with plant procedures.
STAR's 2-950522 (May 16,1995),2-950407 (April 17,1995),2-950883 (August 15, 1995)
I These STAR's identified voids in masonry block walls that are fire walls. Probe holes were drilled to identify extent of the voids and repairs were made to fill the voids.
NCR-4672-3038C (June 28,1994)
This NCR addresses degraded fire doors. The NCR required the repair / replacement of these doors.
Reactor Auxiliary Building / Control Building NCR-2-574 (March 9,1994)
This NCR identified a door that was severely corroded. The NCR provided repair / replacement instructions for the subject door.
Fuel Handling Building STAR 1-960432 (March 21,1996) l Embedde'd steel angles around an opening in the concrete wall were identified as being i
corroded and causing the concrete to spall adjacent to the toe of the angles. The corrosion from the base metal of the embedded plates was removed, and the degraded concrete was removed. The angles were coated and the joint between the angle and j
the concrete was caulked.
l NCR-4669-3040C (June 28,1994)
This NCR identifies a corroded exterior door. Repair instruction were provided with the l
NCR disposition.
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f ATTACHMENT 1 to the Scoping Document for the implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures intake Structure l
STAR's 1-94110333 (November 3,1994) and 1-94110447(November 17,1994) l l
These STAR's docurnant thst connections for ladders attached to embed plates had i
significant corrosion and had separated from the embed plate at two locations.
Severely degraded embeds were removed including the nelson studs and etainless steel plates and expansion anchors were used to support the ladders. Concrete and existing supports were repaired and coated in accordance with plant procedures.
STAR 1-950606 (June 5,1995).
This STAR documents cracks on the underside of the concrete slab of the intake bays 4
1 A1,1 A2,181, and 182. The STAR gave instructions for the removal of the degraded concrete and materials for repair of the structure.
STAR 2-951911 (November 20,1995) l This STAR documents a bolt for a missile shield that was broken during maintenance activities, PCM 205-295 was issued for the repair of the broken bolt.
Component Cooling Water ArealStructure l
CR 96-1068 (May 24,1996) i Building support steel which was used to support a valve actuator was significantly degraded due to corrosion. A root cause evaluation dete mined that the degradation was due to a lack of coating directly beneath the bearing plate for the actuator. The member was repaired and coated.
l STAR 1-950421 (April 21,1995)
This STAR documents the response to NRC 1R 95-002, that identified several embedded plates in the Unit 1 pit that were covered with water. The inspector expressed concem that water would get beneath the plate and cause undetected damage to the Nelson Stud anchors for the embed plate. The evaluation concluded that adequate and apparent warning signs, such as plate bulging and concrete damage would pitvide evidence of nelson stud corrosive damage, f
STAR 1-950452 (April 27,1995)
This STAR documents an area of spalled concrete and deteriorated rebar at the base 3
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l ATTACHMENT 1 l
to the Scoping Document for the Implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures l
of the 2A and 2B heat exchanger pedestal wall. The degradation is at the location of a 4" weep hole. The weep holes appeared to have been created by being chipped out after the wall was poured. No sleeve was installed. The STAR provides direction for removci and repair of the degraded concrer and rebar and instalistion of PVC pipe sleeve to protect the reinforcing steel.
i Steam Trestle NCR N/A-3005C (May 10,1993)
This NCR documented a concrete t:ench cover / missile shield that has a broken corner and provided repair / replacement instructions.
Turbine Generator Building STAR 1-950338 (March 23,1995)
The north-east pier of the 1 A1 water box was found to have cracking and spalled surfaces. The root cause for the degraded area was attributed to improper construction techniques associated with the installation of the grouting for the bearing plate. The STAR provided direction for the removal of the degraded concrete and repair for the pier.
STAR 1-94110334 (November 3,1994)
An area of spalled concrete was documented on the edge of a cantilevered section of the elev.19.5 floor slab. This STAR provided for the removal and repair of the degraded concrete.
STAR 2-94120534 (December 6,1994)
The expansion joints located in the floor of the west condensor pit have deteriorated, which resulted in corroded rebar and spalled concrete. The STAR provided direction for the removal and repair of the degraded concrete and repair and details for the repair of the expansion joints.
NCR-N/A-3001C (April 28,1993) l This NCR identified cracks, exposed rebar and missing anchor bolts associated with the Unit 1,1 A Heater drain cooler pedestal, El 19.5. This item was previously documented via NCR 1-703 and repair instructions have been issued per PC/M 561-191.
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ATTACHMENT 1 to the Scoping Document for the implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures NCR-6466-3017C (November 4,1993)
This NCR documented a voids under the concrete laydown slab between the two TGB's. These voids were attributed to degraded expansion joints and were evaluated and based on the evaluation, repair instruction were provided.
Diesel Generator CR 96-747 (May 10,1996)
Identifies cracks on the west face of the 1 A Diesel Generator Building in the west radiator exhaust plenum area. The cracks were determined to be surface cracks only and did not affect structuralintegrity of the building.
STAR 1-951746 (November 6,1995)
This STAR identifies a crack in the 1B EDG roof. This was determined to be a structural crack through the full thickness of the roof. A required actions as a result of the STAR evaluation were to repair the crack by sealing it with an epoxy grout, and sealing the entire Unit 1 diesel generator roof with a elastomeric urethane coating.
Engineering recommendations were to coat the U2 diesel generator building, CCW building, and diesel oil tank structure.
Tanks CR 96-844 (May 14,1996)
Inspection of the interior of the Unit 1 CST have identified deteriorated coatings, incomplete welds, a cracked weld, wet regions, and a region where the dome has buckled. This CR provides for evaluation of the existing conditions and required repairs.
STAR 1-94110442 (November 17,1994)
The Unit 1 RWST manway leaks. This STAR attributes the root cause of the leak to the use of the wrong gasket material by maintenance.
STAR 1-9411405 (November 10,1994)
Unit 1 RWST show signs of exterior corrosion on the bottom of the tank. This STAR provides instructions for addition of a tank liner to ensure leak tightness of the tank.
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ATTACHMENT 1 to the l
Scoping Document for the implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures l
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Intake Canal NCR-6489-3021C (January 5,1994)
This NCR documented a void under a concrete slab used for soil retention at the intake canal. The void was caused by poor grading of the surrounding area causing inadequate drainage ano excessive runoff of water under the slab. The NCR provided instructions for filling of the void using a sand cement mixture and regrading and sodding the surrounding area.
Review of Plant Change Modifications Review of the PCM's issued for repair of structures that are part of the scope of the monitoring program identified the following documents Ultimate Heat Sink Dam PCM 208-193 Addressed repair of an embed located in the Ultimate Heat Sink Dam structure. The damage was caused during welding of an air tank to the embed.
Intake Structure PCM 205-295 This PCM was h, ed to address repair options for a bolt for a missile shield that was broken during maintenance activities.
Review of Plant Work Orders Based on review of the PWO's associated with the repair of plant structures, see listing of specific PWO's reviewed, the items addressed did not appear to be repetitive in nature or indicate that they were maintenance preventable.
A number of similar conditions were identified as part of the inspection of block wa!!s that are part of the fire barrier inspection program. The conditions were documented via the CR process and is discussed above. The condition of these block will continue to be monitored as part of the masonry block wall inspection program for fire barriers.
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ATTACHMENT 1 to the Scoping Document for the Implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures Review of Industry Operating Exoerience A review of Institute of Nuclear Power Operation's Significant Event Evaluation Information Network program was performed on the following words " structural degradation" (49), "structura steel" (95), " reinforcing steel" (7), and " concrete" (244).
The search identified a total of 395 messages containing the search words. Based on a review of these messages none where considered to address degradation of structures that would be applicable to structures at PSL. Most of the degradations identified dealt with system or component related structural degradations, which are not part of this scoping.
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ATTACHMENT 1 to the i
Scoping DoCume ? for the implementation of the Maintenance Rule for Monitoring the Effectiveness of Maintenance on Structures REVIEW OF PWO's THAT APPLY TO STRUCTURES i
BLDG PWO# REMARKS STAR CR PCM OTHER CANAL ~
917333 REPAIR WASHOUT DAMAGE AT INTAKE CANAL CCW 94020625 REPAIR CCW HTX PEDESTAL CCW 95022000 CCW BLDG CONCRETE REPAIR 950452 I
CONTROL 95017806 CONTROL ROOM PENTHOUSE DOOR IS RUSTED OUT EDG 95034191 EDGB SLAB REPAlR (for dramage of standing water)
EDG 96004350 REPAIR 1B EDG ROOF PER STAR 951746 5DG 96011226 FTM CLEAN & DE-SLUDGE DOST 1B & DAY TANK FHB 95022001 REPLACE FHB LARGE DOUBLE DOORS PER STAR 950781
)
FHB 96002939 FHB L SHAPE DOOR CLIP REPA!R FHB 96008331'FHB HATCH GAL REPAIR INTAKE 94020714 REPAlR LADOER IN 1A1 WELL i
INTAKE 94020715 REPAlR LADDER IN 181 INTAKE l
i INTAKE 94024199 DRAINAGE AFTER RAIN AT S. INTAKE i
i INTAKE 94030612 REPAIR WASHOUT AT INTAKE l
INTAKE 96007060-2 REPLACE RUSTED OUT FRAM/ SUPPORT & CAVE l
INTAKE 96008454 01iREPAlR CRACKED CONCRETE AT TRAVELING SCREEN BAYS 950606 RAB 95001575. UNCLOG UNIT 2 FLOOR DRAINS RAB WATER HEATER RAB 95002098 SUPPORT M/M UNIT 1 UNCLOG'A' BATTERY ROOM 7LR DRAIN l
RAB 95015527 BLOCK WALL 889 CELL GROUTING PER STAR 2 950522 950522 l
RAB 95031294 REPAIR LEAK OVER U-1 RAB WEST ENTRANCE BY ELEVATOR RAB 95032486 REPAIR WALL AND FLR PENETRATIONS PER STAR 951815 RAB 95033268.REPAlR WALL #35 RAB EL 28.7 951948 l
'RAB 96007274iREPAIR HVS-4A INTAKE HOOO 960377.
RAB 96012497iREPAIR BW #167 DSR TP WEST STAIRWELL l
l RAB 96012501iFIREWALL BW124 BETWN A & B ELEC. PEN. COL. LINE RA1 RAB 96012501; REPAIR BW #124 (A ELEC PEN RM TO B ELEC. PEN. RM)
RAB 96012538.REPAlR BW 86 ECCS TO -0 5' HALLWAY ABOVE RA4 l
RAB 96012539 REPAIR BW f 6 ECCS TO 0.5 HALLWAY ABOVE RA-5 96-794 I
RAB 9601400m BW 170 RAB EL 43' FIRE ZONE 46 SOUTH WALL j
RAB 96014006' FIRE BW 8168 l
RAB 96014085'BW $161 BETWEEN 1 A AND 18 SWITCHGEAR RM 43' i
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ATTACHMENT 3 TO THE SCOPING DOCUMENT FOR THE IMPLEM'ENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES l
l EXISTING PROGRAMS THAT ARE USED TO MONITOR GENERAL CONDITION OF STRUCTURES AT PSL j
i GENERAL MONITORING REQUIREMENTS FOR ALL STRUCTURES l
j AP 0005750 DUTIES AND RESPONSIBILTIES OF THE SYSTEM ENGINEER ADM-08.02 CONDUCT OF MAINTENANCE AP 0010120 CONDUCT OF OPERATIONS 0-01-99-02 WATCHSTATION GENERAL INSPECTION INSTRUCTIONS Q1-13.2 HOUSEKEEPING AND CLEANLINESS CONTROL METHODS TS 10.2 QUALITY CONTROL SURVEILLANCE OSHA SAFETY DEPARTMENT SURVEILLANCE IN ACCORDANCE WITH OSHA 11 POWER BLOCK STRUCTURE MONITORING AP 0010437 SCHEDULE OF MECHANCIAL MAINTENANCE SURVEILLANCE REQUIREMENTS AP 0010141 OPERATIONS SUPPORT & TESTING (OST) SCHEDULE FOR TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS 1
PRIMARY CONTAINMENT STRUCTURE INSPECTION PROGRAM OI 10.5 TECHNICAL SPECIFICATION SURVEILLANCE INSPECTION OF REACTOR BUILDING SPEC-C-010 PROTECTIVE COATINGS FOR SERVICE LEVEL i APPLICATIONS INSIDE THE REACTOR CONTAINMENT OP 1300052 PERSONEL AND EMERGENCY AIR LOCKS OP-1300051 LLRT OP 1[2]-1300050 ILRT Ol 10.4 ISI INSPECTIONS REACTOR, AUXILIARY BUILDING AP 1800022 FIRE PROTECTION PLAN - FIRE BARRIERS / WALLS / SEALS / DAMPERS AP 1800022 FIRE PROTECTION PLAN - FIRE DOORS (DAILY /6 MONTH)
OP 1-1300054 RAB LEAK TEST DIESEL OIL STORAGE TANKS 5-YEAR PLAN DIESEL OIL STORAGE TANK CLEANING FUEL HANDLING BUILDING OP 2-1600025 FUEL HANDLING BUILDING VENT TEST l
Page 1 a
w--
ATTACHMENT 3 i
TO THE SCOPING DOCUMENT FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE ON STRUCTURES i
i EXISTING PROGRAMS THAT ARE USED TO MONITOR GENERAL CONDITION OF STRUCTURES AT PSL ill LAND UTILIZATION STRUCTURE SPECIFIC INSPECTIONS & TESTS LU-Ol-11.0-4 INSPECTION OF OCEAN INTAKE HEADWALLS j
LU-Ot-11.0-5 INSPECTION OF OCEAN INTAKE MISC. COMPONENTS l
LU-Ol 11.0-7 INSPECTION AND TESTING OF OCEAN INTAKE STEEL COMPONENTS LU-Ol-11.0-8 INSPEOTION AND TESTING OF OCEAN INTAKE SHEAR GATE FOR 16 FT
)
DIAMETER PIPE 4
LU-Ol-11.0 9 INSPECTION OF OCEAN INTAKE 16 FOOT AND 12 FOOT DIAMETER PIPELINES AND VELOCITY CAPS LU-Ol-11.0-11 INSPECTION OF OCEAN INTAKE CANAL BANKS LU-Ol 11.0-12 INSPECTION OF OCEAN INTAKE CANAL CROSS SECTION 1
LU-Ol 11.013 INSPECTION OF OCEAN INTAKE CANAL SLOPE / BOTTOM JUNCTION 2
LU-Ol-11.0-18 INSPECTION OF OCEAN INTAKE BUBBLER P!PE
]
LU-OI-11.0-21 INSPECTION OF OCEAN DISCHARGE HEADWALL l
LU-Ol-11.0-22 INSPECTION OF OCEAN DISCHARGE MISCELLANEOUS COMPONENTS LU-Ol-11.0-24 INSPECTION AND TESTING OF OCEAN DISCHARGE STEEL COMPONENTS LU-OI-11.0-25 INSPECTION AND TESTING OF OCEAN DISCHARGE SHEAR GATE FOR i
j 16 FOOT DIAMETER PIPE I
LU-Ol-11.0 26 INSPECTION AND TESTING OF OCEAN DISCHARGE SHEAR GATE FOR 12 FOOT DIAMETER PIPE 1
LU-Ol 11.0-27 INSPECTION OF OCEAN DISCHARGE 16 FOOT AND 12 FOOT DIAMETER PIPELINES AND DIFFUSERS LU-Ol-11.0-29 INSPECTION OF OCEAN DISCHARGE CANAL BANKS (inner / outer) i LU-Ol-11.0-30 INSPECTION OF OCEAN DISCHARGE CANAL CROSS SECTION LU-Ol-11.0-31 INSPECTION OF OCEAN DISCHARGE CANAL OVERFLOW SPILLWAY LU-OI-11.0-32 INSPECTION OF OCEAN DISCHARGE CANAL SLOPE / BOTTOM l
JUNCTION l
LU-Ol-11.0-38 INSPECTION AFTER MAJOR STORMS lil SYSTEM RESONSIBLE ENGINEER WALKAROUND INSPECTIONS AP 0005750 DUTIES AND RESPONSIBILTIES OF THE SYSTEM ENGINEER i
iv STRUCTURAL WALKDOWNS REQUIREMENTS FOR PLANT MODIFICATIONS i
i 4
1 Page 2 i
4
l i
l PMAI 96-05-023 ATTACHMENT 3 64 PAGES (INCLUDING THIS SHEET) i i
l 1
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IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE ADMINISTRATIVE PROCEDURE REVISION REVIEWED BY APPROVED BY -
DATE FRG ON O
9/26/95 J. Scarola 9/26/95 Plant General Manager 4
6/28/96 J. Scarola 6/28/96 Plant General Manager
- E "
SYSTEM & COMPONENT ENGINEERING epa t n t BMG 7/2/96
REVIStoN NO.:
PROCEDURE Tm.E.
PAGE:
4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 2 of 63 PRocEouRE No.:
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
1.0 TITLE
IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE PROGRAM THIS PROCEDURE HAS BEEN COMPLETELY REWRITTEN, PLEASE READ ENTIRE PROCEDURE BEFORE PROCEEDING
/R4
2.0 PURPOSE
2.1 This procedure provides requirements and guidelines for monitoring the effectiveness of Maintenance in accordance with 10 CFR 50.65.
3.0 REFERENCES
3.1 10 CFR 50.65, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
3.2 Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
3.3 NUMARC 93-01, " Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
3.4 AP 0010432, " Nuclear Plant Work Orders" 3.5 ADM-17.03, " Operating Experience Feedback."
3.6 AP 0010431, " Preventive Maintenance Program."
3'.7 SCEG-01, Nuclear Plant Reliability Data System-(NPRDS).
3.8 AP 0010460, " Critical Maintenance Management."
3.9 Ol 16-PR/PSL-3, " Corrective Action."
3.10 AP 0006130, " Condition Reports."
3.11 OP 0010124, " System Alteration Control."
3.12 OP 0010142, " Unit Reliability - Manipulation of Sensitive Systems."
3.13 OP 1/2-0410022, " Shutdown Cooling."
3.14 NEl 96-03, " Guidelines For Monitoring The Condition of Structures at Nuclear Power Plants," Rev. C, March 14,1996.
~
REVI8loN NO.:
PROCEDURE TITLE:
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 3 of 63 PROCEDURE NO ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT l
4.0 RESPONSIBILITIES
)
4.1 The System and Component Engineering (SCE) Manager is responsible for overall implementation of this procedure and for maintaining an up-to-date list of SSCs within the scope of the Rule.-
4.2 All Plant personnel are responsible for:
1.
Reporting unsatisfactory performance of plant components via the Nuclear Plant Work Order system and/or Condition Report System.
2.
Visual observations (monitoring) of structural conditions during performance of their plant responsibilities (refer to Appendix D),
and day to day general walk around activities, and reporting potential structural degradation via plant guidelines, NPWOs, and/or the Condition Report system.
4.3 The Maintenance Rule Administrator (MRA) is responsible for:
l 1.
Overall coordination of activities conceming the Rule.
2.
Final determinations as to whether system, structure, and l
component (SSC) failures constitute maintenance preventable functional failures.
3.
Dissemination of timely information regarding Performance Criteria and Functional Failures.
4.
Coordination of Expert Panel review and approval activities.
5.
Performance of Periodic Assessments.
4.4 System Owners are responsible for:
1.
Identification of the functions, key components,' programs in place, and Performance Criteria for SSCs (Systems, Structures and Components) within scope of the Rule.
2.
Possessing knowledge of and experience conceming SSCs and their performance.
~
3.
Monitoring SSCs for compliance to performance criteria.
4.
Identifying potential maintenance preventable Functional Failures and bringing them to the attention of Management and the MRA via the Condition Report Process.
i REVISloN No.:
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 4 of 63 PROCEDURE No.:
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
4.0 RESPONSIBILITIES
' (continued) 4.4 (continued) j 5.
Identifying when SSC performance criteria has_treen exceeded l
and/or repetitive MPFFs occur to facilitate prompt review by the MRA and expert panel.
i 6.
Providing root cause determination for SSCs when performance criteria are not met, when functional failures occur, or when l
otherwise required.
7.
Providing input on the establishment of goals and/or corrective actions for SSCs as conditions warrant.
8.
Monitoring goals established for SSCs (Systems, Structures, and Components) in category (a)(1), as requested.
l 9.
Providing input on whether the increase in risk from removing l
equipment from service for PMs is balanced by a gain in reliability.
- 10. Providing input on applicable risk / reliability considerations in the l
basis for changing PMs.
i
- 11. Maintaining Maintenance Rule system summaries up to date.
- 12. Incorporating industry operating experience as appropriate.
4.5 The Expert Panel is responsible for:
~
1.
Review and approval of the following activities:
A.
Systems, structures, and components within the scope of the rule l
B.
Assignment of risk significance C.
Performance Criteria D.
Performance Monitoring activities E.
Goal setting and monitoring actions (i.e. dispositioning from (a)(2) to (a)(1))
i
REVtSON No.:
PROCEDURE Tm.E.
PAet 4
IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 5 of 63 peocEcuRE No.
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
4.0 RESPONSIBILITIES
(continued) l 4.5 (continued) l l
1.
(continued)
G. Completion of corrective action (i.e. dispositioning from (a')(1) j to(a)(2))
H. Periodic Assessments 4.6 De PSA (Probabilistic Safety Assessment) Engineer is responsible for providing risk evaluations as requested to include the following:
l 1.
initial determination of risk significance for SSCs (Systems, Stnactures and Components) in scope.
I 2.
Evaluating risk when goals must be established.
l l
3.
Evaluating risk when removing equipment from service to perform
)
j preventive maintenance.
4.
Evaluating whether the increase in risk from removing equipment from service for PMs is. balanced by a gain in reliability.
- 5.0 DEFINITIONS-1 l
5.1 The following definitions apply:
1.
The Maintenance Rule (Rule) - 10 CFR 50.65, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, as shown in Appendix A.
i 2.
SSCs - Structures, Systems, and Components that are within the l
scope of the rule. Section (b) of 10 CFR 50.65 provides the criteria for inclusion. A current list is shown in Appendix B.
3.
Functional Failure - A failure of a system, structure, component, or train such that the system, structure or train is not capable of performing its intended function (s) (i.e., the function (s) that required the SSCs inclusion within the scope of the rule).
r
REVISloN No.:
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 6 of 63 PeocEoURE No..
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
5.0 DEFINITIONS
(continued) 1.
(continued) 4.
Maintenance Preventable Functional Failure - AK unintended event or condition such that a SSC within the scope of the rule is not capable of performing its intended funebons (i.e....the functions performed by the SSC that required its inclusion within the scope of the rule) and that should have been prevented by the performance of appropriate maintenance actions.
5.
Repetitive Maintenance Preventable Functional Failure - A second t
l Maintenance Preventable Functional Failure (same cause) that occurs following an initial Maintenance Preventable Functional Failure and implementation of corrective action, within two operating cycles.
6.
Section (a)(1) - The section of 10 CFR 50.65 that requires goal setting and monitoring for SSCs. At St. Lucie this designation indicates performance needs improvement.
7.
Section (a)(2) - The section of 10 CFR 50.65 that permits exemption from monitoring under section (a)(1). At St. Lucie this designation indicates performance is satisfactory.
8.
Maintenance - The aggregate of those functions required to preserve or restore safety, reliability, and availability of plant structures, systems, and components. Maintenance includes not only activities traditionally associated with identifying and correcting actual or potential degraded conditions, i.e., repair, surveillance, l
diagnostic examinations, and preventive measures; but extends to l
all supporting functions for the conduct of these activities.
(Source: Federal Register Vol. 53, No. 56, Wednesday, March 23, 1988, Rules and Regulations /Page 9340).
9.
Preventive Maintenance (PM) - The set of activities that includes all deliberate, preplanned maintenance, testing, or observation of SSCs. This includes preventive maintenance procedures, computerized PMs, surveillance testing, calibrations, overhauls, and condition monitoring such as log taking and inspection.
i l
l l.
.m.
. ~. _ _ _ -.
Revision No.:
PROCEDURE TTTLE:
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 7 of 63 PaoCEDURE No..
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
5.0 DEFINITIONS
(continued) 1.
(contirs,d) j 1
- 10. Performance Criteria (Criteria) - Performance Criteria are j
established for all SSCs to set a standard for adequate performance. Performance Criteria are reasonab.le objectives that 1
permit a pre-analyzed level of failures and routiiie maintenance.
I Failure to meet Performance Criteria puts an SSC into (a)(1) and goal setting.
i
- 11. Unavailability - The amount of time, over a given reporting period, l
that a system or train is not operational when required: that is, either not in operation or not capable of being put into operation if demand requires it.
- 12. Reliability - A measure of the expectation that a SSC will perform its function upon demand at any future instant in time. The measure of reliability will be based on maintenance preventable functional failures.
l l
- 13. Eauivalent Availability Factor - The ratio of gross availability i
generation to gross maximum generation, expressed as a percent.
l
- 14. Goal Settina and Monitorina - When performance does not meet l
Performance Criteria, goals must be set. Goals may be more specific objectives to address the reason that performance is not acceptable. Goals may also be the same as N original Performance Criteria. The SSC is then moniW,d against the goal.
l
~
Goals must be met to move a SSC back into (a)(2). If corrective actions are taken, they must be monitored for effectiveness prior to l
moving the SSC back into (a)(2).
f
- 15. Periodic Assessment - An overall evaluation to., establish effectiveness of maintenance actions. Performance and criteria are j,
compared and may be adjusted. This evaluation will review and trend the disposition of SSCs into (a)(1) and (a)(2) that may have l
occurred during the period covered by the report. It will also include any changes to the scope,
- 16. Exoert Panel-A designated group of managers and department j
[
heads who are responsible for review and approval of the l
implementation of the Rule. This group is identified by title ind will l
routinely assemble to review and approve Periodic Evaluations and other program attributes.
REVISloN No.:
PROCEDURE TTTLE.
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 8 of 63 PRocsouRs No..
ADMINISTRATIVE PROCEDURE ADM-17.08 i ST. LUCIE PLANT
5.0 DEFINITIONS
(continued) 1.
(continued)
- 17. Workina Group - A group formed for the initial _idiplementation of the Rule. Members consisted of varying groups.of engineers and supervisors from the three main maintenance d.isciplines, Technical Staff, an SRO from Operations, and a PSA engineer. The purpose of the Working Group was to create the System Summaries.
- 18. System Owners - Those persons designated as responsible and accountable for overall cognizance regarding assigned SSCs and for the performance of actions required to implement the 1
Maintenance Rule.
- 19. System Summaries - A system Summary has been written for each system that is within the scope of the Rule. The System Summaries document the reason that applicable SSCs are in -
scope, the safety functions of the system, key components needed to perform the functions, and programs in place to ensure the components will function when required, and applicable performance criteria.
- 20. Industrywide Operatino Experience - Information included in NRC, Industry, and vendor equipment information that are applicable and available to the nuclear industry with the intent of minimizing i
adverse plant conditions or situations through shared experiences.
This included NPRDS, INPO documents, NRC Notices, vendor recommendations and Nuclear Network information.
- 21. Qualified Inspector - A degreed engineer with five (5) years related civil / structural experience and/or a Professional Engineering License in Civil / Structural Engineering. In addition to the above requirements, the qualified inspector shall be s.ufficiently trained and experienced in the design, analysis and inspection of large structures associated with nuclear power plants.
i
- 22. Normally inaccessible Areas Portions of structures that are underwater Areas of high radiation Areas that would represent an extreme safety hazard without specialized equipment j
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(continued) 1.
(continued) l
- 23. Permanently inaccessible Areas l
Portions of structures that are underground.
i Portions of structures that are concealed tfy the presence of other permanent structures 6.0 RECORDS REOUIRED:
6.1 When completed, the following documentation associated with this procedure shall be maintained in the plant files in accordance with Ui 17= PR/PSL-1, " Quality Assurance Records."
1.
The following elements of Maintenance Rule implementation are documented via the Corrective Action Program (Condition Reports and PMAls) and are controlled as OA Records:
i i
A.
Cause Determinations 1
B.
MPFFs C. Corrective Actions D.
Goal Setting and Monitoring i
2.
Reports documenting evaluation of Maintenance Rule elements (in accordance with Section (a)(3) of the rule):
l A.
Maintenance Rule Quarterly Reports B.
Periodic Assessments l
4 l
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7.1 Introduction 1.
The Maintenance Rule,10 CFR 50.65 (Appendix A), outlines a process by which SSCs that are important to nuclear safety are identified, categorized by risk significance, and monitored using j
performance criteria to ensure satisfactory perf6rmance. If SSC i
performance does not meet the specified criteria, the rule prescribes a process that provides heightened sensitivity towards j
the identification and correction of the problems responsible for the l
deficiencies.
~2 Expert Panel 1.
The System and Component Engineering Manager is the Chairman of the Expert Panel. The Maintenance Rule Administrator may act as attemate Chairman. The remainder of the Expert Panel shall consist of personnel from the following departments / disciplines:
A.
System and Component Engineering B.
Probabilistic Safety Assessment C.
Maintenance D.
Operations E.
Outage Management F.
Site Engineering / Maintenance Specialists l
l 2.
Expert Panel members should have a working understanding of the Maintenance Rule, and should have a broad kr}owledge of plant operations, rnaintenance, and safety analysis. The System and Component Engineering Manager shall approve all members. A list of approved members will be maintained. The results of Expert Panel meetings shall be documented.
3.
The minimum quorum for an Expert Panel meeting shall consist of the Chairman or attemate Chairman and three members. A.s a minimum, members representing SCE, PSA, and Operations shall 1
be present. Consultants from other disciplines may be relied upon by the Expert Panel as needed.
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(continued) 7.2 (continued) 4.
The Expert Panel shall review and approve (as riecessary) the following:
A.
Determination of Maintenance Rule scope-5 irid SSC risk significance.
B.
Performance criteria and changes to performance criteria.
C.
Initial disposition category for Maintenance Rule SSCs and changes to SSC disposition category.
D.
Goals developed for SSCs requiring goal setting and l
monitonng.
E.
Cause determinations and corrective actions that are a result of an MPFF. (This review may be performed after approval of the Condition Report that documents the MPFF.)
F.
Periodic Assessments.
7.3 Scope Determination and Risk Significance 1.
All SSCs that meet at least one of the following criteria shall be included within the scope of the Maintenance rule and this procedure:
i A.
Safety-related SSCs that are relied upon to remain functional during and following design basi:. events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe _ shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure 2
comparable to the 10 CFR 100 guidelines.
B.
Non safety-related SSCs that are relied upon to mitigate accidents or transients.
~
C.
Non safety-related SSCs that are used in plant emergency operating procedures and provide a significant fraction of the ability to mitigate core damage or radiological release.
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(continued) 7.3 (continued) l 1.
(continued)
D. Non safety-related SSCs whose failure cou.id. prevent safety-related SSCs from fulfilling their safeity-related function.
l E.
Non-safety related SSCs whose failure could cause a reactor trip or actuation of a safety-related system.
2.
For each SSC determined to be within the scope of the Maintenance Rule, the Expert Panel shall determine risk significance. In determining if a SSC is risk significant, the Expert l
Panel should consider the following:
l A.
If the Risk Reduction Worth for a SSC exceeds 0.5 percent of the overall core damage frequency, then the SSC should be i
considered risk significant.
l B.
If the SSC contributes to at least 99 percent of the cumulative l
Risk Reduction importances, then the SSC should be considered risk significant.
C.
If the Risk Achievement Worth for a SSC shows at least a.
doubling of the overall core damage frequency, then the SSC should be considered risk significant.
D.
If the SSC appears in the cutsets that comprise 90 percent of l
the core damage frequency, then the SSC should be considered to be risk significant.
E.
If the SSC is required to prevent containment failure or bypass that could result in an unacceptable release, then the SSC should be considered risk significant.
F.
In considering risk significance, all modes of operation and all failure modes should be considered.
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(continued) 7.3 (continued) d 3.
For each SSC determined to be within the scop 5 of the Maintenance Rule, a System Summary shall be. developed. The System Summaries shall document Maintenance. Rule function (s),
key components, relative risk significance and sxisting PM programs in place.
A.
Functions describe the SSCs Maintenance Rule functions, provides a basis for evaluating failures, and demonstrates why the SSC is scoped within the Maintenance Rule.
B.
Key Components are listed to indicate those components whose failures may prevent fulfillment of a Maintenance Rule function. This listing b intended to provide guidance on what components could impact Maintenance Rule functions and therefore is not inclusive of all system components.
C. PM programs are listed to show what preventive maintenance activities are performed to ensure continued SSC operability..
4.
The basis for including SSCs within the scope of the Maintenance Rule, SSC System Summaries, and SSC risk significance determinations shall be reviewed and approved by the Expert Panel.
73 Performance Criteria 5
1.
Performance criteria are used to determine whether SSC performance is maintained at an acceptable level.
2.
Specific (SSC Level) Performance Criteria A.
Performance criteria shall be specified at the system, train or component level for risk significant and standby non-risk significant SSCs.
6
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(continued) 1 7.4 (continued) 2.
(continued) l B.
Performance criteria for risk significant SShs.and standby non-risk significant SSCs shall be specifiedin terms of Unavailability, Reliability, or Condition as appropriate.
)
l 1.
Unavailability i
I t
1 i
A.
Unavailability measures the time that a system or train is unable to perform its intended function against the time it is needed. Out of service hours may be used.
B.
Unavailability shall include periods of both corrective and preventive maintenance if the system or train is required to be in service.
C.
For standby components that are found failed, unavailability starts at the time of discovery. Assumed l
unavailability (half the time since last known operable) l shall not be used.
l D. Administrative unavailability will not adversely count against performance monitoring indicators.
EXAMPLE For, example, if scaffolding is built over a train, the train may be placed in the out of service log for administrative reasons. If the train'is still capable of fulfilling its functions, it is considered available for Maintenance Rule.
E.
Unavailability performance criteria'should be evaluated for PSA considerations as appropriate unavailability probabilities. The PSA assumes an unavailability probability for certain trains and components that, if exceeded, could potentially impact the estimated core l
damage frequency.
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(continued) j 7.4 (continued)
~
2.
(continued) j B.
(continued) y j..
2.
Reliability f,
A.
Reliability provides a measure of the expectation that an available SSC will perform its function upon demand at any future instant in time.
i B.
Reliability may be monitored using performance criteria based on maintenance preventable functional failures.
C.
Reliability may be measured by performance of l
surveillances and calibrations.
i j
3.
Condition 4
A.
Condition typically includes vibration, flow, i
temperature, allowed leakage, and other similar parameters. Conditinn may be monitored by j
inspection data acquisition or by record /logkeeping i
activities.
j 3.
Plant Level Performance Criteria I
A.
For non-risk significant, non-standby SSCs, plant level performance criteria may be established and monitored.
1.
Equivalent Availability Factor l
A.
For SSCs in which a loss of structure, component,
[
train, or system directly affects plant power output, Equivalent Availability Factor (EAF) may be used for Performance Criteria.
B.
The criteria is the Nuclear Division EAF goal per previous 12 months based on 836 MW.
C.
Downpowers as listed in the Outage Report shall be used in the determination of the FAF.
i I
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(continued) 7.4 (continued) 3.
(continued)
A.
(continued) 2.
Unplanned reactor trips j
a.
Unplanned Engineered Safety Feature (ESF) actuations (Reportable per 10 CFR 50.72) 4.
Unplanned " red" SSA during outages l
5.
Unplanned, reportable radiological releases (Reportable per 10 CFR 20 and 10 CFR 50.72)
B.
Non-risk significant, non-standby SSCs may also be monitored against SSC level performance criteria.
C.
Plant level performance criteria may also be applied to all
. systems, including those which also have specific performance criteria.
7.5 Changes to Maintenance Rule Scope and Performance Criteria 1.
If changes to scope or performance criteria are necessary, a form similar to Figure 1 shall be used.
2.
The following process shall be used to complete the form:
A.
List the SSC. Include system name, number, train, and component tag ID if applicable.
B.
Indicate whether or not the SSC is risk significant.
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(continued) 7.5 (continued) 2.
(continued)
)
C. Discuss the change and indicate if an addkion or a deletion.
1.
Cite specific criteria 2.
Cite reason for change D.
Reference any documentation of change (PCM, drawing #,
EOPs).
i E.
Discuss any change to system safety functions.
F.
List the key components affected by the change.
G. List any changes to programs in place (changes to preventive maintenance and condition monitoring programs).
H.
Discuss any change that impacts relative risk significance. The PSA Engineer or designee should be consulted when risk information is needed.
l l
l.
List any change to Performance Criteria and indicate any necessary additional bases.
j l
J.
If any of the above steps are not applicable, indicate the reason.
3.
The change shall be recommended by the Maintenance Rule i
Administrator and/or other knowledgeable indivjdual (i.e., JPN, PSA, PCM). The review shall be documented by the signature (s) of the applicable individual (s).
4.
The change shall be reviewed and approved by the Expert Panel.
A.
Approval of the Expert Panel shall be documented by the i
Expert Panel meeting date and signature of the chairman of the Expert Panel. The change is effective of the date of approval.
l l
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(continued) 7.6 (a)(2) Preventive Maintenance and Condition Monitoring 1.
Under the provisions of the rule, goal setting and mo jtoring are not required where it can be demonstrated that the performance or condition of an SSC is being effectively controll.ed,through the performance of appropriate preventive maintenince such that it remains capable of performing its intended (Maintenance Rule) functions.
2.
Individual, specific preventive maintenance and condition l
monitoring ar:tivities are not a commitment under the Maintenance j
Rule; only that performance is controlled by effective preventive maintenance. PMs and condition monitoring activities may be l
added, deleted, or changed, as, long as the performance or condition of an SSC is effectively controlled.
3.
Condition monitoring may be accomplished as part of maintenance activities in many ways.
A.
Individuals may report degradations or failures via the Nuclear.
Plant Work Order (NPW0) system.
B.
Routine inspections and calibrations may be used to find degradations before failures are apparent. Discrepancies are reported in NPWOs.
C. Specific data collection and trending may be performed by a number or departments. Action levels may be informal.
Individuals who recognize adverse trends may use the NPWO system, the Condition Report Process, intemal memos or direct communication to bring the situation to the appropriate level of attention. Action levels may also be formaj, documented in procedures, and include required corrective actions.
D. The extent of condition monitoring may vary from structure to structure, system to system and component to component, depending on importance to risk.
m.
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(continued) 7.6 (continued) 4 2
J 4.
Performance monitoring shall be accomplished By tracking Specific (SSC Level) and/or Plant Level Performance Criteria and repetitive maintenance preventable functional failures. While goal setting and monitoring are only required when performance has been demonstrated to be unacceptable, the responsible system owner should monitor the performance of SSCs in order to identify adverse trends before they result in Performance Criteria not being met.
5.
Performance indicators should be tracked by the responsible System Owner in a format similar to Figure 2.
6.
Structural Condition Monitoring A.
Performance monitoring typically used for systems and components which rely on active indication such as flow or change of state are generally not applicable or sufficient for structures. Condition monitorinn is generally more effective means of monitoring the perfomiance of structures.
B.
All structures within the program shall be monitored to identify degradation which could impair the performance of the structure.
C. Plant Level Condition monitoring of structures shall be accomplished using the following methods:
1.
Initial Baseline Condition Survey Baseline surveys shall be performed by a qualified inspector to initially establish the specific extent and type of degradation existing in structures that are within the scope of the Maintenance Rule. Initial Baseline surveys as a minimum shallinclude:
a.
Name of structure being assessed b.
Date of inspection c.
Name of the inspector (s)
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(continued) 7.6 (continued)
I 6.
(continued)
C. (continued) l 1.
(continued) d.
An evaluation of the structure using the applicable inspection attributes listed on Figures 7 thru 10, as guidance 4
i e.
The sun /ey should identify:
- 1. Deficient or unacceptable conditions
- 2. Conditions that deviate from normal, but are considered acceptable (e.g., a rust stain on a concrete wall caused by corroded reinforcing bar that was repaired). This type of information reduces the time required to research this condition during future inspections.
- 3. Areas that are inaccessible. Note the reason the area was inaccessible. Areas that are normally inaccessible shall be inspected at the first opportunity not to exceed five years from implementation of the Maintenance Rule (i.e, July 10, 2001).
f.
Other documentation as required to describe a discrepant or unacceptable condition (e.g.
photographs, drawings, etc.).
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(continued) 7.6 (continued) 6.
(continued)
C. (continued)
.[..
2.
Periodic Condition Survey Periodic surveys shall follow the format of the initial baseline survey and be performed at repetitive intervals throughout the life of the plant. Their purpose is to determine the type a.'d extent of structural degradation and to provide a basis for trending the changes from previous inspections. The baseline survey should be l
updated to include the information of the periodic surveys.
l The periodic condition survey should initially be performed l
at intervals not to exceed five years. The Maintenance Rule Administrator may shorten the inspection intervals if it
!s deemed necessary, based upon information such as the results of structural condition assessments, on-going l
general monitoring activities, unusual events, or industrywide operating experiences.
l 3.
General Monitoring Activities l
l A.
Several procedures and processes are alreaciy in place at PSL which monitor the condition of structures at PSL (See Appendix D). These existing programs L
are used collectively to identify potential and actual degradation of the conditions of structures that are l
part of the program. Structural monitoring guideline structural deficiency reports and n)ethods identified in section 7.6.3 may be used for identifying potential areas of structural oegradation.
l B.
A qualified inspector should preliminarily assess l
l potential areas of structural degradation to identify the l
level of action that is required. Action levels are identified in section 7.6.3.C.
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(continued) t 7.6 (continued) 6.
(continued) l C. (continued) i l
4.
Unusual Events A qualified inspector should perform a condition survey on all structures affected by an unusual event. The results of i
this survey should follow the format of the baseline survey i
and be documented in the periodic condition survey.
Areas of potential structural degradation should be identified to the level pf action that is required. Action levels are identified in section 7.6.3.C.
5.
Industrywide Operating Experience l
If review of industrywide operating experience as required in section 7.11.3.B.1, indicates that a structure of l
structures may be subject to potential visible degradation, a condition survey should be performed by a qualified inspector. This survey should be documented in the periodic condition survey. Areas of potential structural degradation should be identified to the level of action that is required. Action levels are identified in section 7.6.3.C.
D.
Baseline and Periodic Condition Survey Results Assessment Based on the results of the Base or Periodic Condition Surveys a qualified inspector should perform an assessment of the results. Based on this assessment, each structure within the scope of the Maintenance Rule should be identified as one of the following:
1.
Acceptable Acceptable structures meet the performance criteria and are free of deficiencies or degradation which could, lead to possible failure.
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(continued) 7.6 (continued)
~
j 6.
(continued) j D. (continued)
I 2.
Acceptable with Deficiencies Structures which are acceptable with deficiencies are those which meet the performance criteria, but are degraded or l
have deficiencies which could deteriorate to an unacceptable condition, if not analyzed or corrected prior to the next scheduled examination.
i 3.
Unacceptable l
Unacceptable structures do not meet the performance i
criteria. An unacceptable safety related structure should be classified as a functional failure according to the Maintenance Rule.
E.
A Condition Report for any condition identified during the baseline of periodic condition surveys that constitutes a MPFF or determined to be deficient or unacceptable as defined above shall be initiated. The condition report shall be traceable to the assessment documentation.
I 7.7 Maintenance Preventable Functional Failures 1.
SSC Maintenance Rule functions are listed in the System Summaries.
2.
A failure that affects a SSC Maintenance Rule function as listed in the System Summaries should be considered a functional failure.
3.
A Maintenance Preventable Functional failure (MPFF) is an unintended event or condition such that a SSC within the scope of the rule is not capable of performing its intended (Maintenance l
Rule) function and that should have been prevented by the j
performance of appropriate maintenance actions.
i l
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(continued) 7.7 (continued) 4.
Failure of any system's function will be evaluate 3 at the train level when appropriate. This will ensure that for risk, significant and non-risk standby systems, each MPFF will be iderttified at the train level, so that functional failures on one train ars not masked by the continued operability of a redundant train.
A 5.
A repetitive MPFF is a maintenance preventable functional failure
]
that occurs more than once within two operating cycles.
j 6.
A repetitive MPFF is the subsequent loss of function that is attributable to the same maintenance related cause that has i
previously occurred on the same component type.
j A.
A second or subsequent loss of function that results from a i
different maintenance related cause is not considered a repetitive MPFF.
i l
B.
If insufficient time exists between failures to identify and i
perform corrective actions, the failures are not repetitive.
1 j
7.
A repetitive MPFF may occur on equipment in different trains, systems, or units.
7.8 Cause Determinations 4
j 1.
A cause determination shall be performed for any of the following:
1
-A.
A goal not being met.
B.
A performance criteria not being met.
t i
C.
A functional failure of a risk significant SSC, even if the goal or l
performance criteria is met.
D.
A repetitive MPFF of any SSC within the scope of the Maintenance Rule, even if the goal or performance criteria is t
j met.
i 2.
All cause determinations shall be documented as Condition Reports
]
in accordance with AP 0006130, " Condition Reports."
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(continued) 7.8 (continued) 3.
The cause determination should identify the catise of the failure or unacceptable performance, whether the failure was a MPFF, and whether or not it was repetitive. It should identify.any corrective 1
action to preclude recurrence, and make a detsrmination as to whether or not the SSC should be dispositioned as (a)(1)(Section 7.9).
4.
Cause determinations shall consider any generic implications for SSCs other than the one being evaluated. In addition, industry wide operating e.xperience should be considered where appropriate.
5.
The level of detail required for a cause determination varies according to the failure, the sicjnificance of the SSC, whether a MPFF is involved, or whether a performance criteria was exceeded.
The cause determination may be a simple assessment of an obvious case, or may require a rigorous and formal root cause analysis.
6.
If plant level performance criteria are exceeded, the cause determination should identify the SSC(s) which contributed the largest adverse impact.
7.9 (a)(1) Goal Setting and Monitoring (Dispositioning from (a)(2) to (a)(1))
1.
SSCs are subject to goal setting and monitoring under section (a)(1) of the rule whenever-A.
Performance criteria are not met due to maintenance related causes.
B.
Repetitive MPFFs occur.
C. A cause determination recommends goal setting and monitoring.
2.
A form similar to Figure 4 should be used for initiating the Goal Setting and Monitoring process.
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(continued) 7.9 (continued) 3.
The form shall be completed by the responsible system owner in
)
the following manner:
~
A. List the SSC affected.
B. List whether or not the SSC is risk significant.
q C. Indicate whether performance criteria have been exceeded or a repetitive MPFF occurred. if both, select both. If a cause determination recommended (a)(1) status consideration due to a failure of a risk significant SSC, even if performance criteria were met, then provide explanation.
D. If performance criteria have been exceeded, describe the event (s). Include the unit, date, and time of the occurrence (s).
E.
Explain which criterion was exceeded.
F.
If a repetitive MPFF occurred, summarize the reason that the failures are considered repetitive. The' Condition Reports that document the failures may be referenced or attached.
G. List sources of reference information. Examples are: NPWOs, LERs, lHEs, trending reports, operator logs, and Figure 2.
Reference documents should be attached.
4.
The responsible System Owner shall perform or assign the following steps. A form similar to Figure 4 should be used and linked with the Condition Report initiated in step 7.9.7.
A.
Specifically identify that the SSC is being assigned (a)(1) status.
B.
Determine the responsibility for root cause analysis. When complete, summarize, reference and attach the original document.
(
C.
Determine corrective actions and responsibility.
4 i
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(continued) j 7.9 (continued) i 4.
(continued)
D. Set goals and determine the monitoring req'uirements and methods to verify goals are met.
1.
Goals can be set at the structure, system, train, or component level as appropriate. The level at which a goal is set should be such that the goal brings about the necessary improvement in performance.
E.
Include frequency and duration of monitoring and date of reassessment.
F.
Include a discussion of the method by which goals were set to be commensurate with plant safety (PSA) or why this was not practical.
G. Include the method by which industry wide operating experience was taken into account or why this was not practical. Possible sources are: NPRDS, Nuclear Network, Vendor Bulletins, Operating Experience Program, NRC Notices, NSSS Owners Group Information, or direct contact with peer utilities or equipment vendors / manufacturers.
]
NOTE A review of related Industrywide Operating Experience should be performed as a preliminary step in the establishment'of corrective actions, goals and monitoring.
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(continued) 7.9 (continued) 1 7.
The MRA shall process the Goal Setting and Monitoring form and supporting information using the Condition Report procedure to
)
ensure adequate management review and traceab.ility.
l 8.
The MRA shall arrange for Expert Panel review of the proposed goal setting and monitoring process.
i l
9.
If the Expert Panel review does not concur that the situation j
requires monitoring under section (a)(1) of the Rule, Figure 4 (or i
similar) and the Condition Report generated in 7.9.7 should be j
dispositioned with a basis for not requiring monitoring. If a j
Technical Assessment is deemed necessary to provide a basis for i
j not placing a SSC into (a)(1) status, Figure 3 (or similar) may be l
used.
j A. The reason should be transmitted to the MRA along with a i
i copy of the Condition Report.
B. The Expert Panel may decide an SSC is of low risk
)
significance and may be run to failure. Under these circumstances, a change to scoping may be warranted.
j C.
If the Expert Panel identifies a need for relaxation of the s
}
Performance Criteria, a change should be initiated.
D.
Documentation of the change should provide the new criteria i
and use PSA and industry wide operating experience, as l
applicable, to justify the change.
l E. A form similar to Figure 1, Changes to Scope or Performance Criteria, shall be used and sent to the MRA.
i
)
- 10. Monitoring should be performed for each corrective action to verify effectiveness. Monitoring may be as simple as post maintenance testing of a replaced part. Monitoring may be as irwolved as daily I
condition monitoring on the affected component and t l s milar i
components until all can be replaced.
l
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 29 of 63 peOCEDURE NO ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
7.0 INSTRUCTIONS
(continued) 1 7.9 (continu9d)
- 10. (continued) l A.
If during monitoring, SSC performance does.rtot meet a specified goal, or a failure of a risk significant SSC occurs l
l (even if the goal or performance criteria is met), a cause determination shall be required and the goal setting and monitoring reevaluated.
- 11. Applicable goals must be met before an SSC can be retumed to (a)(2) Effective Performance status.
NOTE For standby equipment that has experienced functional failures during surveillances, the NRC has stated that successfully passing three routinely scheduled surveillances is adequate monitoring.
7.10 Completion of Goal Setting and Monitoring (Dispositioning from.
a(1) to a(2))
1.
A goal may be determined to have been met., monitoring of SSC performance against specific goals may be discontinued, and the i
SSC may be retumed to the provisions of (a)(2) if any of the following criteria are satisfied:
A.
Performance is acceptable for three surveillance periods where the surveillance periodicity is equal to or less than a six month interval; B.
Performance is acceptable for two successive surveillances where the surveillance periodicity is greater than six months but no greater than two fuel cycles; or C. An approved and documented technical. assessment assures the cause is known and correctsd and thus monitoring against goals is unnecessary.
I 2.
When the responsible System Owner and the MRA agree that any of the above conditions have been satisfied, an SSC may be l
dispositioned from (a)(1) to (e)(2), using a form similar to Figure 5, Demonstration of (a)(2) Effective Performance.
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IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 30 of 63 PeoCEDURE NO i
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7.0 INSTRUCTIONS
(continued) 7.10 (continued) 1 3.
The form shall be completed in the following manner by the
}
responsible System Owner.
A.
The initial reason for entering (a)(1) should'be' given.
I i
B.
A discussion of corrective actions and monitoring should be provided including the extent to which they were successful in achieving the goals.
2 C.
Required changes made to PMs or condition monitoring 4
activities should be summarized. This section should l
demonstrate how the PM program or condition monitoring effectively controls the performance of SSCs. These changes i
1 should be documented in the PM basis or an applicable procedure or guideline in accordance with the requirements goveming those programs.
D. The Demonstration of (a)(2) Effective Performance form (Figure 5) shall be sent to the MRA. This form also must be used to close a PMAI resultant of the Condition Report initiated j
in section 7.9.7.
f E.
The Expert Panel shall concur that the SSC is ready to be j
moved into (a)(2) as indicated by signature of the Expert Panel Chairman.
P F.
If a periodic evaluation is due but some monitoring will continue into the next cycle, Figure 5 (or similar) should be completed.
Corrective actions and monitoring should be designated as either completed or open. Those still open.should have a new review date included.
i f
7.11 Periodic Assessment 1.
In accordance with Section (a)(3) of the Rule, performance and i
condition monitoring activities and associated goals and preventive maintenance shall be evaluated at least every refueling cycle l
provided that the interval between evaluations does not exceed 24 months.
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 31 of 63 PepcEDURE No.:
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
7.0 INSTRUCTIONS
(continued) 7.11 (continued) 2.
The evaluations will be performed by the following methods:
A.
System Owners shall monitor SSCs for corripliance to performance criteria in accordance with thii procedure. The results of SSC performance, SSCs considered for goal setting and monitoring per section (tD) of the rule, as well as SSC degradations, trends and pertinent industry wide operating experience should be reported to appropriate site personnel (typically System Owners, Expert Panel members, and Plant Management) as Maintenance Rule Quarterly Reports.
B.
A higher-level, comprehensive periodic evaluation should be performed annually at mid; year following Maintenance Rule implementation dates. This evaluation will be i@ntified as the Periodic Assessment.
3.
The scope of the Periodic Assessment shall encompass (for the period covered by the report):
A.
The review of goals and the results of monitoring activities established for SSCs being monitored under (a)(1) of the Maintenance Rule. This review should evaluate SSC l
performance against respective goals and should also evaluate each goal for its continued applicability.
B.
The review of the results of monitoring activities as related to performance criteria for SSCs under (a)(2) of the Maintenance Rule. This review should determine if performance was acceptable on an overall basis. If performance was not acceptable, the cause should be determined and corrective action initiated.
1.
Industrywide operating experience, where appropriate, should be reviewed to identify potential problems that are applicable to the plant. Reviews should confirm that l
industry operating experience has been properly considered and evaluated with regard to existing i
maintenance and monitoring activities. Reviews should j
determine if industrywide operating experience indicates the need to change existing programs.
4
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 32 of 63 PeoCEDURE No.:
i ADMINISTRATIVE PROCEDURE j
ADM-17.08 ST. LUCIE PLANT j
7.0 INSTRUCTIONS
(continued) 7.11 (continued) 3.
(continued)
C. The review of corrective actions taken as k'r.e.sult of ongoing maintenance activities or goal setting to erisure ac Sn was initiated when appropriate, and that action (s) taken resulted in improved performance of the SSC. Corrective actions that should be reviewed include the following:
1.
Actions to ensure that SSC performance met goals established by requirements of (a)(1);
2.
Actions taken as a result of cause determinations; 3.
Status of problem resolution, if any, identified during the previous periodic assessment.
D. Review and trending of SSCs dispositioned from (a)(2) to (a)(1) and SSCs dispositioned from (a)(1) to (a)(2), and the review of.
the basis for these actions.
E. The identification of changes to maintenance activities that may result in improving the relationship between availability and reliability.
F.
A review of repetitive MPFFs to evaluate the effectiveness of the corrective action program.
4.
The Periodic Assessment should be conducted for both units-concurrently. The following approach should be used to conduct the periodic assessment.
A.
System Owners provide input to the Maintenance Rule Administrator on the goals, performance criteria, functio:ml failures, corrective actions, performance, etc. assoc..
2.vith l
the system since the previous assessment.
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4 IMPLEMENTATION OF 10 CFR 50.65, i
l THE MAINTENANCE RULE 33 of 63 PRDCEDURE No l
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7.0 INSTRUCTIONS
(continued) 7.11 (continued) l 4.
(continued)
B. The Maintenance Rule Administrator will consolidate inputs from System Owners, review corrective aedons taken, assess SSC and overall Unit performance, assess the continued appropriateness of goals and performance criteria, discuss any necessary changes to scoping or risk significance, and (with assistance from PSA) address the balance between unavailability and reliability. The methodology used to consider, evaluate and apply, where appropriate, industrywide operating experience since the previous assessment will be assessed.
C. The Maintenance Rule Administrator will prepare a Periodic l
Assessment report which discusses these topics, the effectiveness of corrective actions, any areas where improvement is needed, and provides conclusions which summarize the effectiveness of the maintenance programs which implement the rule.
D. The Maintenance Rule Aoministrator will present the Periodic Assessment report to the Expert Panel for review and approval.
7.12 Balancing Unavailability and Reliability 1.
Adjustments shall be made where necessary to ensure that the objective of preventing failures of SSCs through maintenance is appropriately balanced against the objective of minimizing unavailability of SSCs due to monitoring or preyentive maintenance.
2.
The objective of balancing unavailability and reliability is taken into account when Maintenance Rule Performance Criteria are established. PSA results are used to determine unavailability-l values which, if met. would ensure that certain threshold Core Damage Frequency values would not be exceeded. Maintenance Rule performance criteria values are established in accordance with PSA results. Additionally, performance history, preventive '
maintenance activities, and out of service time are taken into consideration when developing performance criteria. Therefore, a j
reasonable balance of unavailability and reliability is demonstrated when SSCs meet performance criteria.
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 34 of 63 PeoCEDURE NO ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT
7.0 INSTRUCTIONS
(continued) 7.12 (continued) u 3.
Optimization of preventive maintenance may be achieved by any of the following:
A.
Ensuring that appropriate preventive maintInance is performed to meet availability objectives as stated in plant risk analysia, l
FUSAR, or other reliability approaches to maintenance.
l l
B.
Allocating preventive maintenance to applicable tasks commensurate with anticipated performance improvement (e.g., pump vibration analysis instead of teardown).
C. Reviewing to determine that availability of SSCs has been acceptable.
l D.
Focusing maintenance resources on preventing those failure modes that affect a safety function.
l l
E.
Scheduling, as necessary, the amount, type, or frequency of preventive maintenance to appropriately limit the time out of service.
l 7.13 Evaluation of Systems to be Removed from Service i
1.
In performing monitoring and preventive maintenance activities, an j
assessment of the total plant equipment that is out of service l
should be taken into account to determine the overall cifect on performance of safety functions.
2.
The NPS/ANPS/NWE is responsible for autherizing work on operable systems and ensuring that the plant is in a safe condition.
A.
The Nuclear Plant Supervisor or designee makes a qualitative assessment when he gives permission to start work on a Nuclear Plant Work Order and takes equipment out of service.
l B.
Only the NPYANPS/NWE may authorize removal of l
equipment. Removal means any act which precludes the system or component from performing its intended function.
C.
Redundant equipment is required to be operable when l
removing Technical Specification equipment from service.
l l
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 35 of 63 i
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7.0 INSTRUCTIONS
(continued) 7.13 (continued) 3.
The Operations / Maintenance Coordinator coordi6ates trouble and breakdown work w.th Operations surveillances or Maintenance PMs to minimize equipment out of service time.
l t
.=
4.
The PSA group has developed pre-evaluated maintenance risk assessments. Outage Management and Operations personnel should use these risk assessments to ensure that plant system trains or components taken out of service comply with PSA evaluated risk assessments. In the event that the pre-evaluated maintenance risk assessments do not provide risk assessment for a proposed plant configuration, a specific PSA assessment will be required prior to entering the proposed configuration.
5.
Equipment required by a Technical Specification Limiting Condition l
for Operation may be voluntarily taken out of service for preventive maintenance if the increased safety risk during the period in which the equipment is dnavailable due to maintenance is offset by the decreased safety risk attributable to the improved reliability of the.
equipment following maintenance. A specific or pre-evaluated risk assessment may be used to evaluate the safety impact, This process is govemed by AP 0010460, "Criticai Maintenance Management."
6.
During maintenance testing and operation of sensitive systems it may become necessary to perform manipulations. Two related sensitive systems should not be worked at the same time.
The Shutdown Safety Equipment Assessmerkt is used to show the 7.
relative risk of each safety function based on available equipment.
Safety functions are those defined in Emergency Operating Procedures. This qualitative assessment is intended to heighten personnel awareness of unit conditions.
1 l
8.
The procedure for shutdown cooling outlines plant equipment l
required to be operable and other work controls for this operational l
mode.
l l
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IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 36 of 63 peocsous m.
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT APPENDIX A THE MAINTENANCE RULE (Page 1 of 2)
$ 50.65 Requirements for monitoring the effectiveness of maintenance at j
nuclear power plants.
(a)(1)
Each holder of an operating license under 69 50.21]b) or 50.22 shall monitor the performance or condition of structures, systems, or components, against licensee established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components, as defined in paragraph (b), are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety and, where practical, take into account industrywide operating experience. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken.
(2)
Monitoring as specified in paragraph (a)(1) of this section is not i
required where is has been demonstrated that the performance or condition of a structure, system, or component is effectively being controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function.
(3)
Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months. The evaluation shall be conducted, taking into account, where practical, industrywide operating experience.
Adjustments shall be made where necessary to ensure that the objective of preventing failures of structures, systems, and components through maintenance is appropriately balanced against the objective of minimizing unavailability of structures, systems, and components due to monitoring or preventive maintenance. In performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performance of safety functions.
(b)
The scope of the monitoring program specified in paragraph (a)(1) of this i
section shall include safety-related and nonsafety related structures, systems, i
and components, as follows:
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 37 of 63
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(1)
Safety-related structures, systems, and components thit are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure Soundary, the. capability to shut down the reactor and maintain it in a cre shutdown cbndition, and the capability to prevent or mitigate the consequence of accidents that could result in potential offsite exposure comparable to the 10 CFR part 100 guidelines.
(2)
Nonsafety related structures, systems, and components:
(i)-
That are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs); or l
(ii)
Whose failure could prevent safety-related structures, systems, and components from fulfilling their safety-related function; or (iii) Whose failure could cause a reactor scram or actuation of a safety-related system.
(c)
The requirement of this section shall be implemented by each licensee no later than July 10,1996.
Dated at Rockville, Maryland, this 28th day of June,1991.
j Signed, Samuel J. Chilk, Secretary or the Commission
- Later changed to once per refueling cycle but less than 24 months.
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 38 of 63 PROCEDURE NO.:
l ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT APPENDIX B SYSTEMS WITHIN THE SCOPE OF THE MAINTENANCE RULE (Page 1 of 2)
RISK SIGNIFICANT SYSTEMS PodormanoiCdtens System & Components SSC Specific SSC $pecific Plant Level D-Availability or Train Level Cetterla 1a RS Fuet and CEAs INPO FRl MPFFs2 PLPC 1,2 1b RS Reactor Coolant System PORVs A, B MPFF52 PLPC 15 2
RS CVCS A, B, C chg pps MPFFs2 PLPC 4 3a RS HPSI A, 8 MPFF52 PLPC 1,3,4 3b RS LPSI A, B MPFFs2 PLPC 1,3,4 3c RS Safety injecbon Tanks A,B,C,D MPFFs2 PLPC 1,3 7
RS Containment Spray A, B MPFF52 PLPC 1,3 8
RS Main Steam MSIV A, B MPFFs2 PLPC 1-3 9a RS Main Feedwater MFIVs MPFFs2 PLPC 13 9b RS Auxilsary Feedwater
'A, B, C MPFFs2 PLPC 1,3 9c RS AFAS EAF" MPFFs2 PLPC 2,3 14 RS CCW A, B MPFFs2 PLPC 1,2.4 17b RS EDG Fuel Oil AB MPFFs2 PLFC 3.4 18b RS Instrument Air C, D MPFFs2 PLPC 1,2 21s RS ICW A, B MPFFs2 PLPC 1.4 25a RS HVAC-Risk Sigtvficant OOS hr: Man MPFFs2 PLPC 1 47a RS 480 VAC swgr & bkrs SSC loads MPFFs2 PLPC 1-4 48 RS 120/208 vac SSC loads MPFFs2 PLPC 1,2 49 RS 120 Vital VAC Inverters MA, B, C, O MPFFs2 PLPC 14 50 RS 125 VDC & chargers A, 8 MPFFs2 PLPC 1-4 52 RS 4.16ky swgr & bkrs AB & SSC loads MPFFs2 PLPC 1-4 53 RS Generanon & Distnbuton A & B S/U xfmts MPFFs2 PLPC 1-4 59 RS EDGs A, B, t:1ggers MPFFs2 PLPC 1,3,4 63 RS RPS EAF" MPFFs2 PLPC 2,3 63 RS Contasnment Penetranons ILRT & LLRT MPFF52 PLPC 1,4 69 RS ESFAS & Annuncators EAF" MPFFs2 PLPC 2-4,6 PLANT LEVEL PERFORMANCE CRITERI A PLPC 1 Unplanned unavadability less than or equal to 5% for each unit, last 12 rnonths PLPC 2a Unplanned automanc reactor trips less than or equal to 1 for the site for last 12 months.
Unplanned rnanual reactor trips less than of equal to 2 each unit for last 12 months.
PLPC 2b PLPC 3 Unplanned ESF Actuanons less than or equal to 1 each urut for last 12 months.
PLPC 4 Unplanned
- Red
- SSA during less than 1 each outage.
PLPC5 Unplanned, reportable radiological release less than or equal to 1 from the arte during the test 12 months.
PLPC 6 Unplanned, reportatne loss of annunoabon in the control room less than or equal to 1 last 12 months.
Repeneve Maintenance Preventable Funcnonal Failures less than 1 per 36 months appues to all SSCs and may occur between trains, units, or different systems invoMng similar components.
DEFINITIONS PLPC
- Plant Level Performance Cnteria.
- Maintenance Preventable Funcnonal Failure.
l RMPFF Repettve Maintenance Preventable Funcnonal Failure.
Availability - Tracked by OOS log hours in Modes 13 only, total over prevous 18 months.
l Reliabilrty - Tracked in ALL rnocos, MPFF s2 on any sinale train in any 18 rnonth penod.
i Effectveness of problem soMng RMPFF < 1 in any 56 montn penod.
EAF" Less than 1% urut unavailability loss / year attnbutable to a spoofic SSC.
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4 IMPLEMENTATION OF 10 CFR 50,65, THE MAINTENANCE RULE 39 of 63 PROCEDURE NO.:
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT APPENDIX B SYSTEMS WITHIN THE SCOPE OF THE MAINTENANCE RULE (Page 2 of 2)
NON RISK SIGNIFICANT SYSTEMS.-
Pemwmano ceneria System & Cv,6,~,
SSC Specde SSC Specific Plant Level AvaHatukty or Train Level Crtlerta Condidon Rehatukty 4
NRS-S8 Fuel Pool MPFFs2 PLPC 4,5 6
NRS-S8 Waste Management MPFFs2 PLPC 5 23a NRS-SS SGBD Red Monrtonng MPFFs2 PLPC5 l
25b NRS 88 HVAC Non Risk MPFFs2 PLPC 1,?
25n NRSS8 ECCS Drams MPFFs2 PLPC 5 26 NRS68 Radiation Moneonng MPFFs2 PLPC 3,5 27a NRS-S8 Hydrogen Analyzer MPFFs2 PLPC 1 27b NRSS8 Hydrogen Recomtuners MPFFs2 PLPC1 37 NHS-SS Ultimate Heat Sink Valves MPFFs2 PLPC1 60 NRS-S8 Staton Groundog MPFFs2 PLPC 1,3 62 NRS-SS Reactor Reguanng MPFFs2 PLPC 13 64 NRS-38 Nuclear instrumentaton MPFFs2 PLPC 13 70 NRS-88 OSPDS MPFFs2 PLPC 1 73 NRS-S8 Structres inspeceons MPFF50 PLPC 1 75 NRS S8 Cadiode Protecton MPFFs2 PLPC1 10 NRS Extracton Steam PLPC 12 11 NRS Hester Drams and Vents PLPC 12 12a NRS Condensate PLPC 1,2 13 NRS Tusbine Coobng Water PLPC 1-2 17a NRS Turbine Lube Oil PLPC 1,2 1
19 NRS Condensate Polishing PLPC 1,2 21b NRS Circulatng Water PLPC 1,2 22 NRS Turtune PLPC 1,2 46 NRS 6.9 kv swgr & bkrs PLPC 1,2 47b NRS 480 VAC swgr & bkrs PLPC 12,4 66 NRS CEDM PLPC 1,2 67 NRS Fuel Handtog PLPC 1 74 NRS Polar Crane PLPC1 PLANT LEVEL PERFORMANCE CRITERIA PLPC 1 Unplanned unavadatniity less than or equal to 5% for each urut, last 12 months.
PLPC 2a Unplanned aummaec reactor inps less than or equal to 1 for the sie for last 12 months PLPC 2b Unplanned manual reactor inps less than or equal to 2 each urut for last 12 months Unplanned ESF Actuanons less than or equal to 1 each unit for last 12 monens.
PLPC 3 PLPC 4 Unptarened " Red
- SSA dunng less than 1 each outage.
Unplanned, reportable radeiogeal release less than or equal to 1 from the arte dunng the last 12 rnanths.
PLPC5 Unplanned, reporta06e loss of annunaabon m the control room less than or equal to 1 last 12 monens PLPC 6 Repestve Mamtenance Preventable Functonal Fanures less tnan 1 per 36 months applies to all SSCs and may occur between trams, units, or different systems involving smear components.
DEFINITIONS I
PLPC Plant Level Performance Criteria.
MPFF Maintenance Preventable Func00nal Failure.
l RMPFF
- Repettive Maintenance Proventan6e Funcconal Failure.
Avedat>hty. Tracked by OOS log hours n Modes 13 only, total over previous 18 months.
l.
Renatmhty Tracked in ALL modes, MPFF s2 on any encio tren m any 18 month period.
i Effecoveness of proclem solving - RMPFF < 1 in any 36 montn penod.
Less than 1% urut unavalabil#ty loss / year attnbutable to a specdc SSC.
EAF" Non Risk Sigruficant NRS Standby Systems SB
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 40 of 63 PROCEDURE NO..
l ADMINISTRATIVE PROCEDURE l
ADM-17.08 ST. LUCIE PLANT APPENDlX C STRUCTURES INCLUDED IN PSL MAINTENANCE RULE MONITORING PROGRAM l
Reactor Building: Shield Building Containment Vessel Interior Structure Reactor Auxiliary Building Fuel Handling Building l
Steam Trestle Diesel Generator Building intake Structure l
l Component Cooling Area Structures, including pipe trenches l
Ultimate Heat Sink Dam Refueling Water Tank & Foundation I
Condensate Storage Tank Condensate Storage Tank Shielding Diesel Oil Storage Tank Diesel Oil Storage Tank Pumphouses Turbine Building Flood Protection Stop Logs (Unit 2 RAB and South door on East wall)
Main Transformer Barrier Walls & Foundations Start-Up Transformers Barrier Walls & Foundations Auxiliary Transformers Foundations l
Cooling Canals:
Intake Head Wall Intake Pipe Line Intake Velocity Cap Seal Well Structure Discharge Head Wall Discharge Piping 1
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4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 41 of 63 1
Psocsouns no.
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT APPENDIX D EXISTING PROGRAMS FOR SURVEYING STRUCTURAL PERFORMANCE General Monitorina Reauirements for All Structures The following procedures have been revised to address genei:al monitoring requirements of structures and supports as required for implementation of the Maintenance Rule:
AP 00'1750 -
Duties and Responsibilities of the System Engineer Engineers are responsible for monitoring and evaluating their system's equipment and components. This requires maintaining detailed knowledge of as-built design, review of operating and maintenance records, frequent walkdowns and discussions with operating and maintenance personnel.
Structures are system 73.
ADM 08.02 -
Conduct of Maintenance Maintenance functional unit is responsible for surveillance, preventive, predictive, planned and corrective maintenance, and implementation of modifications for plant structures, to assure optimum plant performance.
AP (410120 -
Conduct of Operations t
Operations is responsible for the day to day operation of the plant to ensure safe, efficient and reliable operation. This requires daily detailed surveillance of the plant operation to identify system deficiencies and initiate corrective actions.
O1 - 13.2, " Housekeeping and Cleanliness Control Methods" TS 10.2, " Quality Control Surveillance" Safety Department Surveillance in Accordance with OSHA flequi'rements I
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4 IMPLEMENTATION OF 10 CFR 50.65, l
THE MAINTENANCE RULE
.42 of 63 mouns m.
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 1 l
Changes to Scope or Performance Criteria SSC # and
Title:
Unit:
1
.2 (circle) l 0 Risk Sig.:.0 Non Risk Sig.
This change is:
O an addition 0 a deletion i ~
l Description cd Change:
l l
References (attach):
i l
i impact of change on functions:
i i
Change to key components:
l i
(
Changes to Preventive Maintenance and Condition Monitoring Programs:
l Impact of Change on Risk Significance:
Change to Performance Criteria:
i System Owner:
Date:
/
/
i MRA Recommended:
Date:
/
/
Approved:
, Date:
/
/
l Expert Panel Chairman e
l l
l I
MVSON NO.:
PROCEDURE TITLE.
PMAE:
l 4
IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 43 of 63 PROCEDURE NO..
ADMINISTRATIVE PROCEDURE l
ADM-17.08 ST. LUCIE PLANT l
FIGURE 2 SSC PERFORMANCE INDICATOR SSC: 3b LPSI Updat,ecT: 24 April,1996 UNIT: 1
.b Performance Monitorino Period: 36 rnonths Performance Criteria:
l Unavailability: U1 & U2 less than 168 hrs /yr per train OOS (4 Otr. rolling total).
i Reliability: Less than or equal to 2 MPFFs per train per 18 rnonth period.
PLPC 3: Unplanned ESF Actuations less than or equal to 1 each Unit.
PLPC 4: Zero (0) unplanned ' red" SSA dunng outages.
UNAVAILABILITY Unit 1 LPSI Unavailable Hours 140.00-
/
120m-
/
,/,
g 100.00-S 80.00-
,,,,,,. - + - - - - -
=
Egg 1 A Tram 60.00-M 1B Trah 40 2 -
+.1 A Tram Total 2o.00-
. 1B Trah Total 0.00-Q2 95 0395 04 95 01 96 Penod go,gg Reliability-List att failures (indicate train for risk sig. SSCs), corrective actions and MPFFs:
9/27/94 LPSI - 1B Breaker 20406 failed, adjusted breaker.
5/4/95 - V3206 Breaker 41277 failed, new line starter installed.
PLANT LEVEL PERFORMANCE:
Report PLPC. If PLPC exceeded, determine if SSC was cause.
PLPC 3: No unplanned ESF Actuations.
PLPC 4: No unplanned " red
- SSA during outages.
Trends:
QI 96 OOS Hrs. attributed to ECCS suction header leak repair (not a MPFF).
I l
l
~ -... _
~.. - - - - ~
_. ~. - - ~ -. _.. -......
REVISION NO.:
PROCEDURE TTTLE:
PAGE:
4 IMPLEMENTATION OF 10 CFR 50.65, PROCEDURE NO.:
THE MAINTENANCE RULE 44 of 63 ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 3 GUIDELINES FOR TECHNICAL ASSESSMENT FORMAT ON NOT PLACING A SSC IN (a)(1) IF PERFORMANCE CRITERIA IS NOT MET l
These guidelines are intended to aid the System Owner in proiliding the basis for not placing an SSC in a(1) classification when its performance. criteria are not satisfied.
1 Describe the conditions and event sequence regarding the MPFF.
11 Describe the root cause and contributing factors.
lll Describe the corrective actions taken.
(A copy of the LER or SCE Problem Report may be referenced and attached for I.11 and 111.)
IV Explain why the MPFF is not repetitive.
V Explain the impact of the MPFF on PSA.
VI Assess the applicability of the MPFF to the other unit.
Vil Explain how the multiple barriers put into effect will preclude a repetitive MPFF.
l Prepared by:
Date:
/
/
Reviewed by:
Date:
/
/
A draft of the Technical Assessment shall be provided to the Maintenance Rule Administrator for scheduling of a review by the Expert Panel. The SSC owner will sponsor the assessment at the panel. A final assessment will be issued after approval by the panel.
i i
l
FEVISION NO.:
PROCEDURE TITLE.
PAGE:
4 IMPLEMENTATION OF 10 CFR 50.65, P90CEDURE NO.:
THE MAINTENANCE RULE 45 of 63 ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 4 (Page 1 of 2)
Goal Setting and Monitoring.
~
Unit: 1 2 Date:
Risk Significant:
. 0 Yes 0 No SSC:
i ~
Reason for goal Setting:
Performance Criteria Not Met Which Criteria were not met?
l l
Description of Events:
l Repetitive MPFF (attach Figure 3 for each failure)
Explain how failures are repetitive.
Were previous corrective actions inadequate?
l l
l References (attach):
a l
Does this SSC require (a)(1) status?
Oyes 0 No System Owner l
Yes - signature of Expert Panel Member l
Maintenance Rule Administrator No - signature and reason why not Expert Panel Chairman
~
REVISION NO.:
PROCEDURE Trrt.E:
PAGEb a
4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 46 of 63 m.as no.
ADMINISTRATIVE PROCEDURE I
ADM-17.08 ST. LUCIE PLANT FIGURE 4 (Pege 2 of 2)
Goal Setting and Monitoring Root Cause Analysis:
Assigned To:
J -
Corrective Actions and Responsibilities:
Assigned to:
1.
2.
3.
4.
Goal Setting and Monitoring: For each corrective action, there should be a goal to be attained that shows the action was correct, monitoring for a follow-up period to verify success, and a discussion to show how PSA and industrywide operating experience were used in the process.
Goal Monitoring method & frequency Date PSA/ industry Exp 1.
1.
2.
2.
3.
3.
4.
4.
Prepared by:
Systern Owner Date Review and Concurrence:
Maintenance Rule Administrator Date Review and Approved:
Expert Panel Chairman Date
m m.
-m pm 4
IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 47 of 63 peoceouns m a ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 5 Demonstration of (a)(2) Effective Performance Unit: 1 2 Date:
Risk Significant:
- 0 Yes 0 No SSC:
i '
Initial reason for entering (a)(1) goal setting and monitoring Date:
i For each corrective action and goal:
Did the corrective action meet the goal?
Was monitoring successful?
Were any changes made to the PM or condition monitoring program?
Summarize.
Expert Panel Review All corrective actions were performed and were successful in achieving goals. The SSC may be retumed to (a)(2) status.
SSC must remain in (a)(1) status for the following r'eason(s):
Prepared by:
System Owner Date Review and Concurrenge:
Maintenance Rule Administrator Date' Approved by:
j Expert Panel Chairman Date
.. - _ - ~. ~-.
.~-. - -.
i REVISION NO.:
PROCEDURE TITLE.
PAGE:
4 IMPLEMENTATION OF 10 CFR 50.65s THE MAINTENANCE RULE 48 of 63 emOURE NO.
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT i
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nevlSloN No.:
PROCEDURE E H.
PAGE:
4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 49 of 63 pomag so,.
ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT i
FIGURE 7 REINFORCED CONCRETE SURVEY CHECKLIST (Page 1 of 4)
Person (s) Performing Survey Date of Survey
/
/
1.
i 2.
Structure of Structural Component Being Surveyed Zone #
Review For indication of Potential
Dearadation:
Any visible cracks wider than Y,............................ Y ES / NO Notes:
Evidence of spalling, scaling, stratification........................ YES / NO Notes:
)
Evidence of water infiltration.................................. YES / NO Notes:
i Exposed rebar............................................ YES / NO Notes:
Evidence of the presence of any rebar corrosion................... YES / NO Notes:
Rust bleeding, staining, or discoloration.......................... YES / NO Notes:
~
Evidence of corroded or icose inserts......................,.... YE S / N O Notes:
Spalls 6r pop-outs which exceed a depth of 1' or exposes rebar '........ YES / NO Notes:
~-
Spalling or scaling which also exhibits delamination (hollow sounding).... YES / NO Notes:
Peeling, discolored, or detenorated coatings....................... YES / NO Notes:
Evidence of concrete erosion or chemical attack.................... YES / NO Notes:
Other Attach additional sheets for documentation of potentially degraded items. Documentation snould include location, sketmes, and or pctures (indicate direction of view), suspected root cause or actions required to identify root cause. Refer to attacned sheets in notes acove. as applicaele.
i REWWoN No.:
PROCEDURE MLE:
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4 JMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 50 of 63 peocsouRs No ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT l
FIGURE 7 REINFORCED CONCRETE SURVEY CHECKLIST (Page 2 of 4)
^
j Concrete Surveillance Terminoloov _
1 BLEEDING CHANNELS Passageways left by escape of excess water during drythg and settlement.
CHEMICAL DETERIOP ?. TION Deterioration of concrete due to chemical attack.
l CHLORIDE ATTACK l
Chlorides and nitrates of ammonium, magnesium, aluminum and iron attack l
concrete. Sodium chloride is harmless to concrete, but is a major contributor to corrosion of rebar.
CRACKING Separation of concrete into parts characterized by length, width and depth and whether the crack is active or passive. Passve cracks may be caused by construction errors, shrinkage, variations in intamal temperature, or shock waves. Active cracks may be caused by variations in atmosphere or intamal temperature, absorption of moisture, reinforcement corrosion, chemical reactions, settlement, or various loading conditions.
DELAMINATION L
A horizontal splitting cracking or separation of concrete member in a plane l
roughly parallel to and generally near the surface; found most frequently in deck slabs and caused by corrosion of rebar; similar to spalling or scaling, or peeling except that delamination affects large area and is not readily apparent without sounding.
l DETERIORATION l
Impairment of usefulness of concrete DISCOLORATION Departure of color from that which is normal or desired; usually caused by staint or cherreical changes DISINTEGRATION Deterioration into small fragments or particles due to factors such as l
chemical attach, weathering and erosion.' l-
REVISloN No; PROCEDURE TrTLE. PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 51 of 63 P90CEDURE Noa ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 7 REINFORCED CONCRETE SURVEY CHECKLIST (Page 3 of 4) Concrete Surveillance Terminoloav, (continued)
- ~
DISTORTION Warping or deforming of concrete due to factors such ras overloading, poor design, ground movement, and expansion. EFFLORESCENCE Deposit of water soluble chemicals, usually white on concrete surface. EROSION Progressive surface disintegration of concrete by the abrasive or cavitation action of gases, fluids or solids in motion. HONEYCOMB Voids left in concrete due to lack of adequate vibration, inappropriately low slump, or congestion of the embedded steel. \\ POPOUTS The breaking away of small potions of a concrete surface due to intemal pressure which leaves a shallow, typically conical depression. Popouts may be caused by rebar corrosion or cement aggregate reactions. SCALING Local flaking or peeling away of the near-surface portion of hardened concrete or mortar. SPALLING Detachment of fragments usually in the shape of flakes, from a concrete mass. Variations in intemal temperature, corrosion of rebar, chemical reactions, weathering and poor design can cause active spalling. Shock waves or a single incident of varying intemal temperature can cause passive spalling. Passive spalis may simply be repaired but active spalls are wamings of a greater problem. STRATIFICATION The segregation of overwet or over vibrated concrete into horizontal layers with increasingly lighter material toward the top. i l l l
_~ ~ __...__.m._.._ MVIsloN NO2 PROCEDURE TTTLE: PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 52 of 63 P90CEDURE NO4 ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 7 REINFORCED CONCRETE SURVEY CHECKLIST (Page 4 of 4) Concrete Surveillance Terminolooy (continued) f ~ STRUCTURAL PERFORMANCE Excessive cracking or other indications of structural distress due to excessive applied loads, or deformations due to damage from fire or other extemal l I means. UNIFORMITY OF CONCRETE Degree of consistency of the properties of the concrete from one part of the structure to another, UNSOUND CONCRETE j Concrete which has undergone deterioration or disintegration during service exposure. t t l O ^ + 1
~. - -. -. -. ~. - - - -.. -... - -. -. -. - -. - - REVWON No.: PROCEDURE Trn.E: PAGE: l 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 53 of 63 PSOCEDURE No ADMINISTRATIVE PROCEDURE l ADM-17.08 ST. LUCIE PLANT FIGURE 8 l MASONRY SURVEY CHECKLIST (Page 1 of 5) 3 Person (s) Performing Survey Date of Sumey / / 1. 2. 3 ~ Structure of Structural Component Being Surveyed Zone # Review For indication of Potential Decradation: l Any visible cracks wider than 1/16'............................. YES / NO Notes: l Evidence of distortion including bowing, bulging, sagging and warpage... YES / NO Notes: Evidence of water infiltration.................................. YES / NO Notes: ? l Exposed joint reinforcement.................................. YE S / NO Notes: l Evidence of the presence of any reinforcement corrosion............. YES / NO l Notes: Rust bleeding, staining, or discoloration.......................... YES / NO l Notes: i Evidence of corroded or loose top of wall restraints ':S / N O j Notes: i l l Spalls, pitting or detachments................................ YE S / N O Notes: i l I Missing or degraded mortar............................,...... YES / NO Notes: Peeling, discolored, or deteriorated coatings....................... YES / NO Notes: Evidence of masonry / mortar erosion or chemical attack.............. YES / NO Notes: Other Attach addttionsi sheela for documentation of potentially Cegraded items. oocumentation snould include locatum, sketches, and 0 pctures (indicate direction of vks), suspected root cause or actions required to identify root cause. Refer to attacmea sheets in notes above, as apphcable. I J
-. _ _ ~ - _ . - -. -. ~ ~. MEVIS80N NO.: PHocEDURE TTrLa. PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 54 of 63 PaocEDunE m ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 8 MASONRY SURVEY CHECKLIST l (Page 2 of 5) Masonry Surveillance Terminoloov. AIR INLEAKAGE .I.. The volume of air per minute at a measure temperature-iitnd pressure that flows perpendicularfy through a masonry assemblage. Air movement is a i l significant factor affecting condensation. ALIGNMENT The theoretical, definitive lines that establish the position of construction of a masonry assemblage. l BED JOINT LEVELNESS The levelness or deviation from a horizontal plane of the layer of mortar on which masonry units are set. BED WIDTH VARIATION The variation in thickness of the layer of mortar on which masonry u' nits are set. l BOWING An outward swelling, or protuberance of a portion of a masonry assemblage. BULGING An outward swelling, bowing, or protuberance of a portion of a masonry assemblage from a vertical plane. CHIPPING A condition of small pieces or larger fragments of masonry units se' arating p from the unit resulting from excessive stress. CONDITION OF LINTELS (SHELF ANGLES) l l Vertical, horizontal, or rotating movement of the structural members l supporting masonry assemblages including the connections and connectors of the supporting rr. embers. l CRACKING Narrow fissures from 0.01mm or larger in width in masonry CRAZING The formation of a pattem of tiny cracks or crackles in the glaze of glazed masonry units.
REWBloN No.: PRoCEDuFE TrTLE. PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 55 of 63 PooceouRe No.: ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 8 ) MASONRY SURVEY CHECKLIST (Page 3 of 5) Masonry Surveillance Terminoloav, (Continued) j CRUMBLING A condition indicative of a certain brittleness or tendency of the masonry to break up or dissolve. DEFLECTION / SETTLEMENT Vertical movement of the structure supporting a masonry assemblage. Differential movement is included as well as total movement. DETACHMENT The result of a complete break (or failure of an original construction joint) in a rt_arrf unit in which the detached portion of masonry survives intact. DISPLACEMENT Horizontal translation of all or of a portion of a masonry assemblage. DISTORTION A change in shape of a masonry assemblage. Distortion can include bowing, bulging, sagging, and warpage. EROSION Wearing away of the surface, edges, comers or carved details of masonry slowly and usually by the mutual action of wind or windblown particles and water. EXPOSURE OF JOINT REINFORCEMENT Visible exposure of reinforcing steel bars, masonry ties, anchors, and joint reinforcement providing an opportunity for rapid corrosion of the reinforcement. FRIABLE Mortar or grout that is easily crumbled or pulverized and easily reduced to powder.
( REV won NO.: PROCEDURE Tm.E. PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 56 of 63 j P9ocEDURE No ADMINISTRATIVE PROCEDURE i i ADM-17.08 ST. LUCIE PLANT FIGURE 8 MASONRY SURVEY CHECKLIST (Page 4 of 5) + Masonrv Surveillance Terminoloav (Continued) PEELING l ~ A slipping away of the glaze surface or coating of masonry due to lack of adhesion or improper application of a surface treatment. PITTING The development of small cavities in a masonry surface. PLUMBNESS Deviation of a surface of a masonry assemblage from the vertical. Masonry can be out of plumb and still exhibit no signs of bowing, bulging, sagging, warping, or other distortions. SAGGING A vertical movement of a masonry assemblage characterized by wavy horizontal lines in the surface often accompanied by other modes of distortion. l l l SANDINESS The presence of sand on the exposcd surfaces of mortar and grout indicative of cement deficiency or exces",ive acia washing by cleaning or rain, SPALLING A condition of masonry in which the outer layer or layers of masonry units begins to break off (unevenly) or peel away in parallel layers from the larger block of masonry. ( STAINING i A discoloration of masonry arising from foreign materials. TIES AND ANCHORS Units installed in mortar joints to prevent separation of masonry assemblages at control joints, comers, and wall intersections. Units may be metal tie bars, metal lath, metal strips, wire mesh, or hardware cloth. t
REVISION NOJ PROCEDURE TTTLE. PAGE: 4 IMPLEMENTATION OF 10 CFR 50c65, THE MAINTENANCE RULE 57 of 63 pgOCEDURE NOJ ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 8 MASONRY SURVEY CHECKLIST i (Page 5 of 5) Masonry Surveillance Terminoloav l (Continued) b ' l VOIDS in mortar or grout, the air spaces between and within pieces of aggregate or between units and mortar. 1 WARPING The curvature of a masonry assemblage measured as a deviation from a true plane along the edges or the diagonals of the assemblage. WEATHERING ( Natural disintegration and erosion of masonry caused by wind and rain, resulting in granular and rounded surfaces. l l m' I i
mmmon no.: enoceoune m m. paae: 4 IMPLEMENTATION OF 10 CFR 50.650 THE MAINTENANCE RULE 58 of 63 peoceoune No.. ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 9 STRUCTURAL ST**L SURVEY CHECKLIST (Page 1 of 3) Person (s) Performing Survey Date of Sunray / / l 1. l 2. ( Structure or Structural Component Being Surveyed l Zone # Review For indication of Potential
Dearadation:
j Any flaldng rust............................................ YES / NO l Notes: l Widespread corrosion resulting is section loss of 1/32" in depth of structural elements (i.e. surface rust is not considered reportable but should be considered for future coating issues)............................ YES / NO Notes: l Beam / Column deflection..................................... YES / NO l Notes: l l Pitting or gouges which exceed a depth of 1/32'................... YES / NO. l Notes: l l l Loose or missing anchors / fasteners............................. YES / NO j 1 l Notes-Missing or degraded grout under base plates...................... YES / NO Notes: l ~! l Evidence of cracking (fatigue or fracture)......................... YES / NO Notes: ~ Peeling, discolored, or deteriorated coatings....................... YES / NO Notes: Unsatisfactory condition of connections (i.e. condition, corrosion, deformation, tightness, location, profile, uniformity, cross section)....... YES / NO Notes: Other l l i Attach addllional sheets for documentation of potentially degraded items. oocumentaton should include j loceDon, sketches, and/or pictures (indicate direcDon of view), suspected root cause or actions required to idenlWy root cause. Refer to attached sheets en notes above, as appicable.
l IWVI8loN No.: PROCEDURE Tm.E. PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 59 of 63 PoocEoune No.. ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 9 STRUCTURAL STEEL SURVEY CHECKUST (Page 2 of 3) ^ Structural Steel Surveillance Terminoloav-BRACING OF COMPRESSION ELEMENTS AND MEMBERS.'. Lack of necessary bracing can result in loss of stability,-strength and stiffness of main load carrying elements. CONDITION The physical state as determined by observations and with possible use of simple physical assistance such as cleaning, scraping, and sounding; can be used to establish existence of many physical conditions. CROSS SECTIONAL PROPERTIES Actual or nominal dimensions and other' geometric properties of structural shapes and members. DEFORMATIONS (structural steel) Deformation of members in a metal structure caused by fabrication or erection, out of plane plumbness, lack of fit or slip at connections, settlement or failure of supports, overstressing, inadequate, mechanical properties of materials used, inadequate bracing, change in temperature, removed members or missing connectors, and torsional effects unaccounted for in 2 design. DEFORMATIONS (connections) Elongation, bending, or twisting of bolts, rods, and studs over and above the elastic limit. DIRECT CHEMICAL ATTACK Deterioration of metals by attack of chemical solutions with either low or high acidity. ELECTROLYTIC OR ELECTROCHEMICAL CORROSION (corrosion / rust) Oxidation of metal due to chemical reaction between metal and oxygen and the environment; most common cause of deterioration of unproteted iron and steel products. FATIGUE CRACKING Cracks that develop in ductile materials when the material is subjected to cyclic stresses. These cracks initially propagate slowly and if detected in time, can be treated by taking remedial action. If the cracks are allowed to j l propagate unrestricted, they frequently initiate brittle fracture.
~ REVISloN NO.: PROCEDURE Tm.E. PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 60 of 63 PBocEDURE No.: ADMINISTRATIVE PROCEDURE 1 ADM-17.08 ST. LUCIE PLANT FIGURE 9 STRUCTURAL STEEL SURVEY CHECKLIST (Page 3 of 3) l l Structural Steel Surveillance Terminoloav-(continued) '~ FIRE PROTECTION Strength and stiffness of metals deteriorate significantly when subjected to elevated temperatures. l FRACTURE CRACKING Brittle cracks that take place with little or no preceding plastic deformation. These types of cracks are often triggered by impact or sudden increase in load. GEOMETRY OF STRUCTURE Actual or nominal dimensions defining geometry of structure. IN-SITU STRESSES f The actual stresses that exist in a member representing the sum of manufacturing, fabrication and erection residual stresses and the stresses resulting from in-site loads and deformations. LAMINAR TEARING A planar separation that develops within thick plates near certain large welds as high weld shrinkage develops stresses across the plate thickness. OVERALL OR LOCAL SUCKLING Metal members are relatively slender and usually have thin elements making them susceptible to overall or local buckling. OVERSTRESSING Subjecting metals to stresses in excess of their allowable stresses. NON-BINDING CONDITION Bolts or rods that are not fully restrained from movement by tight fitting nuts. TIGHTNESS' The physical condition of bolts, rods, wire strand, and wire rope that indicates the connector fits snugly and generally under some positive compressive force. UNIFORMITY A measure of the consistency of weld profile, weld size, weld dimensions, weld cross-sectional properties and conditions.
rumssow no-enoceounamia. Paam: l 4 IMPLEMENTATION OF 10 CFR'50.65, THE MAINTENANCE. RULE 61 of 63 P9oCEDunE No.. ADMINISTRA'nVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 10 ROOFING SURVEY CHECKLIST (Page 1 of 3) Person (s) Performing Survey Date of Survey / / 1. g i Structure or Structural Component Being Surveyed Zone # Review For Indication of Potential
Dearadation:
Does roof support system show signs of deflection, bulging, or degradation YES / NO Notes: Are there signs of flashing degradation.......................... Y E S / NO i Notes: Evidence of water infiltration.................................. YES / NO i Notes: I l Does barner material look uniform without cracks or holes that would atM barrier integrity............................................ YES / NO Notes: Is there missing or degraded expansion joint material................ YES / NO Notes: Do any penetrations such as drains or vents appear to be deteriorated... YES / NO Notes: l Evidence of previous root repairs............................... YES / NO Notes: Peeling, discolored, or deteriorated coatings....................... YES / NO Notes: Evidence of detenoration at interface with root mounted equipmenthupport or penetrations............................................ YES / NO Notes: Are gutters and down spouts securely attached and undamaged........ YES / NO Notes: Other i i Attach addedonal sheets for documentation of potentially degraded items. oocumentauon should include locanon, sketches. and/or pctures (indcate direction of view), suspected root cause or accons required to idenefy I root cause, rielet to attached sheets in notes above, as apphcable
REvlSON No.: PROCEDURE M M. Pm 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 62 of 63 PoocEounE No ADMINISTRATIVE PROCEDURE ADM-17.08 ST. LUCIE PLANT FIGURE 10 ROOFING SURVEY CHECKLIST (Page 2 of 3) l Roofina Surveillance Terminolooy ANCHOR SHEET The first sheet applied to a roof deck by nailing, stapling or mopping; often j called a " base sheet." BASE SHEET l One or more layers of organic, inorganic, or glass-fibered felt over which additional roofing materials are applied. l BUILT-UP ROOFING COVER Two or more layers of roofing material as underlayment and surfaced with gravel or slang aggregate, or a cap sheet of smooth or mineral surfaced roofing. l l CAP SHEET l Roofing made of organic or inorganic fibers, saturated and coated both sides with a bituminous compound, surfaced with mineral granules, mica, talc, ilminite or other inorganic fibers, or similar materials. COMPOSITION ROOFING Any asphaltic, prepared roofing material. CONDITION OF ROOFING The degree of the loss of integrity of the material used as roof covering to make itself waterproof. PREPARED ROOF COVERING Any manufactured roofing material as distinguished from built-up roof covenng. ROOF COATING include all roofing membrane which are in a liquid or wet state when applied i by spray, brush, roller, squeegee, or other methods, and which, when cured or dried, form a mechanically stable coating that functions as a roofing covering. j ROOF COVERING, GENERAL Includes any and all systems, coverings, coatings membranes, or combinations thereof which are applied on or over a roof structure primarily to protect a building and its contents against the intrusion of wind, rain, and weather elements.
MMSON No.: PROCEDURE MLe PAGE: 4 IMPLEMENTATION OF 10 CFR 50.65, THE MAINTENANCE RULE 63 of 63 p,pceouRe No ADMINISTRATIVE PROCEDURE i ADM-17.08 ST. LUCIE PLANT FIGURE 10 ROORNG SURVEY CHECKUST l (Page 3 of 3) l l Roofina Surveillance Terminolooy l (continued) 1 ROOFING MEMBRANE 5 ~ Denotes that portion of the roof covering which is intended primarily to provide weather protection and includes single ply and roof coatings. ROOF PAINT l Any and all paint, paint-type, or maintenance type products applied primarity l to change the color, appearance, reflectivity or other cosmetic aspects of the roof, but which have little or no measurable bearing on the functioning of the roof covering. ROOFING SQUARE 100 square feet of roofing surface. ROOFING SYSTEM Any combination of two or more components composing a roof covering including, but not limited to, built-up roofing, single ply foam insulation with compatible coating, metal or plastic panels, roofing-insulation combinations. i SPOT CEMENTING l A discontinuous application of hot asphalt, cold liquid asphaltic compound, hot coal tar pitch or other adhesive. UNDERLAYMENT t One or more layers of felt applied as required for a base, over which prepared roofing is applied. i
l l i i PMAI 96-05-023 ATTACHMENT 4 11PAGES (INCLUDING THIS SHEET)
l l St. Lucie Plant Systems and Components Engineering Department Guideline No. SCEG-003 Revision 0 I i i 1 1 GUIDELINE FOR THE CONDITION SURVEY OF STRUCTURES AND SUPPORTS BY PLANT PERSONNEL Revision 0 A l Approved by: L d Date 7 / i / 4 Systems and Components Engineenng Depanment Heaa Revision: Reviewed by: Date / / Approved by: Date / Systems and Components Engineenng Depanment Head I l
SYSTEMS AND COMPONENTS EN2iNEERING GUIDELINE NO. SCEG-003, REVISION O GUIDELINE FOR THE CONDITION SURVEY OF STRUCTURES AND SUPPORTS BY PLANT PERSONNEL l 1.0 TITLE GUIDELINE FOR THE CONDITION SURVEY OF STRUCTURES AND l SUPPORTS BY PLANT PERSONNEL 2.0 SCOPE 2.1 Purpose This purpose of this document is to provide general guidelines for assessing and reporting the conditions of structures and supports for the implementation of the Maintenance Rule as it applies to structures. 2.2 Discussion These guidelines are intended for use by plant personnel during generai day-to-day walkaround monitoring activities to assist in identifying potential structure and support deficiencies. The monitoring activities are intended to be general in nature and are intended to detect gross areas of cracking, spalling, gouging, corrosion, weld degradation, etc. 2.3 Definitions '1. Structure - Any building, structure, or part of a structure that is identified in Reference 3.1 as being within the scope of 10 CFR 50.65, The Maintenance Rule. 2. geoport - Any support or hanger associated with a system that is identified in Reference 3.1 as being within the scope of 10 CFR 50.65, The Maintenance Rule. 3. Condition - The physical state as determined by observation and possible use of simple physical assistance, such as cleaning, scraping, and sounding. l l sCEG-003. Rev. 0 1 FoR sCE USE
PRE' AUTIONS/ LIMITATIONS 3.0 C l This guideline is intended to assist plant personnel in identifying potential areas L of degradation to personnel trained in evaluation of the condition of structures and supports that will ensure appropriate inspections and corrective actions are taken. It is not intended to replace or prevent the reporting of degraded items l via existing plant processes, such as the Condition Report or Plant Work l Orders. 4.0 RESPONSIBILITIES l Per the references in Section 5.0 of this guideline, the plant maintenance, operations and engineering personnel are required to monitor the condition of j l structures and supports during performance of their general day-to-day l monitoring activities and identify potential deficiencies for assessment and corrective actions. I
5.0 REFERENCES
5.1 ADM-17.08, " Implementation of 10 CFR 50.65, The Maintenance Rule" 5.2 AP 0005750, " Duties and Responsibilities of the System Engineer" l 5.3 ADM-08.02, " Conduct of Maintenance" l l 5.4 AP 0010722, " Plant Management inspection" I l 5.5 AP 0010120, " Conduct of Operations" l l 6.0 RECORDS REQUIRED L 6.1 Structure or Support Deficiency Report - A structure or support deficiency report shall be submitted to identify potential areas of degradation f l SCEG 003. Rev. 0 2 FoR SCE uSE l
7.0 INSTRUCTIONS l 7.1 Identification of Potential Structure and Support Deficiencies The following visual indications can identify potential areas of structure degradation. j 1. Concrete Surface Water in leakage Chemical leaching Peeling paint or discoloration i Exposed rebar j Any crack 1/16" or greater in width Extensive rustbleeding Any crack which exhibits significant rust bleeding Predominant, visible crack pattems Any spall which also exhibits delamination (hollow sounding) Spalls which exceed a depth of 1 inch or exposes rebar 2. Masonry Cracks in joints Deteriorated penetrations Missing or broken blocks 3. Steel Surface / Weld Flaking rust Widespread rust resulting in section loss of more than 1/32" in i depth of structural elements (i.e., surface rust is not considered J reportable, but should be considered for future coatings issues) ) Beam / column deflection Loose or missing anchors / fasteners l Missing or degraded grout under base plates l Twisted beams Pitting or gouges which exceed a depth of 1/32 All cracks or visible indications on welds or structural elements 4 i ScEG-003. Rev. 0 3 FoR SCE uSE
1 7.1 4. Roof Systems Structuralintegrity of support system Deteriorated penetrations (i.e., drains, vents, etc.) Barrier integrKy Signs of water infiltration Cracks Flashing degradation Expansion joint condition 5. Backfill Condition Around Structure Erosion Settlement Slope integrity Seepage Drainage systems The following visual indications can identify potential support degradations, i f 6. Supports j Deformation or structural degradation of fasteners, springs, clamps, or other support beams Missing, detached, or loosened support items Arc strikes, weld spatter, paint, scoring, roughness, or general corrosion on close tolerance machined or sliding surfaces l Improper hot or cold positions of spring supports and constant load supports as indicated on the related support drawing Misalignment of supports l Pitting or gouges which exceed a depth of 1/32 All cracks or visible indications on welds or structural elements Fiaking rust l l SCEG-003, Rev. 0 4 FoR sCE uSE
7.2 Iristructions for Identification of Pot:ntial D:ficiencies 1. Potentially degraded structure or support conditions noted during performance of responsibilities should be documented via a Structural or Support Deficiency Report attached to this guideline. 2. After completing the Deficiency Report, plant personnel shall route j i l report to the Civil / Structural Engineer responsible for Maintenance Rule initial assessment of structures and supports. 3. The Responsible Civil / Structural Engineer shall do a preliminary assessment of the degradation in accordance with Reference 3.1, " Implementation of 10 CFR 50.65, The Maintenance Rule," and verify that all required corrective actions are initiated and completed. ) 1 i l i SCEGM, Rev. 0 5 FOR SCE USE
STRUCTURE DEFICIENCY REPORT This sheet is part of a guideline to be used by plant personnel to assist in identifying potential areas of structural / building degradation. Based on initial assessment of this report by a civil / structural engineer, a corrective action, such as a Condition Report or a PWO, shall be initiated for degraded conditions. UNIT BUILDING / STRUCTURE ELEV. i MATERIAL DEFICIENCY Concrete O Water inleakage O Rustbleeding, staining or discoloration O Chemical leaching / erosion O Predominant, visible crack patterns O Exposed rebar O A crack 1/16" or wider O A spall which exceeds 1" in depth O A spall which exhibits defamination (hollow sounding) Masonry Wall O Missing or broken blocks O Rustbleeding, staining or discoloration O A crack 1/16' or wider O Missing mortar / exposed joint reinforcement O Rusted / loose top of wall restraints Structural Steel O Flaking rust O Pitting or gouges which exceed 1/32' O Missing grout under base plates O Beam / Column deflection O All cracks or visible indications on welds O Twisted beams or structural elements Roof System O Evidence of water infiltration O Damaged barrier material O Missing expansion joint material O Damaged roof support system O Damaged gutters and/or down spouts Backfill Condition Around a Structure / Building O Erosion / washout O slope integrity O settlement O seepage O Drainage systems Coatings of Buildings or Structures O Peeling paint or discoloration O Wide-spread rust Other/ Comments: Attach additional sheets for documentation of potentially degraded items. Documentation should include location, sketches, and/or pictures (indicate direction of view), suspected root cause. Refer to attached sheets in notes above, as applicabl6. Number of attached sheets Reported by Ext. Dept. Date sCEG-003, Rev. 0 ATT 1 FoR sCE usE
SUPPORT DEFICIENCY REPORT This sheet is part of a guideline to be used by plant personnel to assist in identifying potential areas of support degradation. Based on initial assessment of this report by civil / structural engineering, j a corrective action, such as a Condition Report or a PWO, shall be initiated for degraded conditions. SYSTEM NO. SUPPORT MARK NO. UNIT BUILDING / STRUCTURE ELEV. O Deformation or structural degradations of fasteners, springs, clamps, or other support items. O Missing, detached, or loosened support items. O Arc strikes, weld spatter, paint, scoring, roughness, or general corrosion on close tolerance machined or sliding surfaces. O Improper hot or cold positions of spring supports and constant load supports as indicated on the related support drawings. O Misalignment of supports. O Improper clearances of guides and stops. O Flaking rust. O Missing grout under base plates. j O All cracks or visible indications on welds or structural elements. O Pitting or gouges which exceed 1/32". 1 1 O Peeling paint or discoloration. O Wide-spread rust. Other/ Comments: Attach additional sheets for documentation of potentially degraded items. Documentation should include location, sketches, and/or pictures (indicate direction of view), suspected root cause. Refer to attached sheets in notes above, as applicable. Number of attached sheets l Reported by Ext. Dept. Data l sCEG@3, Rev. O ATT 2 FOR sOE USE
STRUCTURES / SUPPORT DEFICIENCY PG # REPORT ATTACHMENT l BUILDING / STRUCTURES / SUPPORT U1/ U2 / COMMON l l l l PLAN / ELEV DIRECTION LOOKING SKETCH OF REPORTED AREA NOTES: I SCEG@3, Rev. 0 ATT-3 FOR SCE USE
9n ST. LUCIE PLANT SYSTEMS & COMPONENTS ENGINEERING GUIDEUNES Rev. 2 Date 07/05/96 INDEX Page 1 of 1 DOCUMENT REV. APPROVAL NO. TITLE NO. DATE SCEG-001 Nuclear Plant Reliability Data System (NPRDS) 1 03/2096 SCEG-002 Maintenance Root Cause Tracking, Potential Repetitive 1 03/20/96 Failures and Component Failure Analysis SCEG-003 Guideline for the Condition Survey of Structures and 0 07/05/96 Supports by Plant Personnel j ) -}}