ML20137P830
| ML20137P830 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/12/1997 |
| From: | WISCONSIN ELECTRIC POWER CO. |
| To: | |
| Shared Package | |
| ML20137P828 | List: |
| References | |
| S-P-97-01, S-P-97-1, NUDOCS 9704100023 | |
| Download: ML20137P830 (55) | |
Text
.
QUALITY ASSURANCE
'h 2OGRAM SURVEILLANCE REPORT
SUBJECT:
Post-Maintenance Testing (PMT)
NUMBER: S-P-97-01 SCOPE: Post-Maintenance Testing performed on PSA systems during 1995-1996 Work Orders (PBNP U2R22 Start-Up Issue #15)
SURVEILLANCE DATES: January 20 - February 10,1997 MONITORED ORGANIZATION: Maintenance, Operations, I&C, Engineering SURVEILLANCE TEAM: , .. . . , .
[~
4)
SURVEILLANCE REPORT DATE: 3/12/97 REPORT PREPARED BY: 6 r
2hp 7
(
REPORT CONTENTS:
C 1
.l.0 EXECUTIVE
SUMMARY
2.0 S P E CI FIC RES ULTS .. . .... .... . .... . .. ....... . .. . . . . .. .. .... . . . . . . . . . . .3 3.0 SURVEILLANCE REFERENCES ..... . ..... .... ... . .. . . .. . . . ................5 4.0 y PERSONNEL CONTACTED.. ........,..,.......
.. .... ... . .. . .. .6 REPORT DISTRIBUTION:
9704100023 970401 PDR ADOCK 05000301 P PDR 3.
.. S-P-97-01 Page1 1.0 EXEC TIVE
SUMMARY
This surveillance was conducted in response to Start-Up Issue Item Number 15 which required a review of the Post Maintenance Testing (PMT) performed on "20% of the work orders performed since January 1,1995 on Unit 2 or common PSA safety significant systems (AFW, SW, EDG, IA,4.16 ky, gas turbine, and CCW) to verify adequate PMT was performed to ensure system / component safety function."
A total of 409 Work Orders (WOs) were randomly selected for review. These were selected from a total population of 1944. The WOs selected and reviewed amount to j 21.1% of the total, exceeding the 20% goal. l l
The surveillance team used the current operational excellence standards as the criteris for reviewing and assessing the selected Post Maintenance Tests (PMT), and not the ,
standards that were in place during the time frame when the PMTs were performed. l The surveillance found that 97% of the Post Maintenance Tests reviewed were effectively iinplemented. Only thirteen WOs were found with inadequate PMT. On those WOs where inadequate PMT was identified, no operability issues exist however, and the systems or components were determined to be able to perform their safety function.
Either the equipment was subsequently tested or operated, thereby verifying its operability.
The following ten specific issues were identified and documented as Quality Condition Reports (QCRs).
QCR 97-0002 - Operability Post-Test not performed as indicated ;
QCR 97-0005 - Failure to follow " continuous use" procedure requirements (*)
QCR 97-0006 - Missing record copy of RMP 9333-1 QCR 97-0007 - Poor documentation of what PMT was done and the results of PMT (*)
QCR 97-0008 - Manual valves not functionally tested following maintenance (*)
QCR 97-0009 - No cross-referencing between WO and procedure (*)
QCR 97-0010 - Potential for non-QA parts used on QA-scoped systems or components QCR 97-0011 - Inadequate PMT and corrective action on DG testing (*)
QCR 97-0012 - Acceptance criteria not adequately justified (*)
QCR 97-0013 - Traceability of PMT records is inadequate (*)
- Multiple occurrences ofissue found.
The use of current higher testing and documentatica standards mentioned above is a contributor to the identification of a number of Quality Condition Reports identified, particularly to those where multiple occurrences were noted.
In addition to the QCRs, nine observations were written. Some propose enhancements to the PMT program, i.e., recording Control Room instrument indications, establishing better consistency in the use of PMT matrices, reducing the reliance on ORT-3 as a basis
-- a
S-P-97 01: Page 2 r
of PMT, and performing calibrations of non-safety related equipment following i installation. One observation proposes better PMT documentation practices,i.e.,
, establishing clearer references in work orders to testing procedures. Finally, some observations document opportunities to improve other programs, i.e., diesel reliability and LCO.-
- i. A brief summary of the Quality Condition Reports and observations is found in
. Attachment A (QCRs) and Attachment B (Observations) to the surveillance checklist. l 3-I As stated above, several issues were found with multiple, not isolated, occurrences. In I order to provide follow-up of some of these issues, QAS will factor them into the QAS
~
Work Activity List. This will provide continued focus on post-maintenance testing during future work monitoring activities.
!' l 7
I 4
1 i
a b g
-1 1
1 ry
S-P-97-01 Page 3 2.0 SPECI$IC RESULTS
' A project plan was developed for this surveillance in support of the Unit 2 Start-Up Issue Item Number 15 requirement which read:
" Review 20% of the work orders performed since January 1,1995 on Unit 2 or .'
common PSA safety significant systems (AFW, SW, EDG, IA,4.16 kv, gas turbine, and CCW) to verify adequate PMT was performed to ensure system / component safety function."
- The project plan also contained the following clarifications regarding the surveillance: j e It applies to all work orders, not just Maintenance work orders (e.g., not just work performed by the Maintenance group, but all work orders in total). ,
e Should significant concerns be identified, the scope of the review will be expanded !
beyond the 20% sample.
- The 20% will be selected in a random manner, using random number generation. t
- Documentation will be made and maintained for the selection / sample process, as well i as documented evidence of each work order review.
To meet the project plan requirements, a random selection from all Work Orders ;
performed in 1995-1996 was performed as described in the Surveillance Plan and Checklist. Testing procedures, Installation Work Packages (IWPs), modification ]
packages, and other records were reviewed, as necessary, to fully review the PMT ;
performed for the Work Orders. 1 The review of each Work Order was documented on a standard form. Issues identified by the reviews were discussed by the audit team. Generic issues were combined and ._. 3 documented as either observations or Quality Condition Reports (QCRs). Attachments A i and B to the Surveillance Plan and Checklist summarize each of the observations and QCRs.
The following table summarizes the Work Orders reviewed by system:
Total No. of '95 '96 No. of WOs System Work Orders Reviewed 4
4.16 kV 161 31 Auxiliary FeedWater 194 40 i Component Cooling Water 168 37 48)
Emergency Diesel' Generator
- 109
- . Gas Turbine 219 44 Instrument Air 228 44
. Service Water 487 104 Total 1944 409 q- ,
S-P-97-01 Page 4 Overall, the' percent of Work Orders reviewed was 21.1% (= 409/1944). A list of the Work Orders reviewed is found in Attachment C to the Surveillance Plan and Checklist. 4 L
-1 4
l
., , e -
j i
I i
i
t 4
S-P-97-01 Page 5 3.0 SURVEiLL ANCE REFERENCES ;
Quality Condition Reports (QCRs) issued: ,
- QCR# Description QCR 97 0002 Operability Post-Test not performed as indicated QCR 97 0005 Failure to follow "contmuous use" procedure requirernents l l
QCR 97 0006 Missing record copy of RMP 93331 j QCR 97 0007 Poor documentation of what PMT was done and the results of PV f Manual valves not functionally tested following maintenance i QCR 97-0008 '
QCR 97 0009 No cross-referencing between WO and procedure i QCR 97 0010 Potential for non-QA parts used on QA4 coped systems or conejonents
=
QCR 97 0011 Inadequate PMT and corrective action on DG testing
' Acceptance criteria not adequately justified QCR 97 0012
, QCR 97-0013 Traceability of PM T records is inadequate ,
Work Monitoring Reports (WMRs) issued: i WMR# Activity Description QCR/ Observation # :
DODC '
- Form QAF-072 was used to document the reviews conducted.
2 Technical Specification (TS) line items audited:
t TS Line item # Description
, N/A 10 CFR 50 Appendix B Criteria audited:
3 CRITERIA ,
i 2 3 4 5 6 7 a'9 10 11 12 13 14 15 16 17 18 P P P P P P P P Fat ull Coverage P= Partial Coverage 5
a f li e
S-P.97 01 Page 6 4.0 PERSdNNEL CONTACTED i
Name TitleLoreanization 1
- .._. .. ,, t
. , . . . v.........
I
..,. ,.... ., . . . . . . . . l i
l r j e
a
, 1 1
) .,
,4. -
i
. , . . . . _ . . _, r r
- L.........,..... l . _ . .
..,_...S j # . . . . . . . . . . , . .
.......,.n .
- Attended exit meeting on 2/10/97
QUALITY ASSURANCE SURVEILLANCE PLAN & CHECKLIST
SUBJECT:
Post-Maintenance Testing (PMT)
NUMBER: S-P-97-01 SCOPE: Post-Maintenance Testing performed on PSA systems during 1995-1996 Work '
Orders (PBNP U2R22 Start-Up Issue #15)
SCHEDULED DATES: January 20 - February 10, 1997 ACTIVITIES TO BE AUDITED:
Post-Maintenance Testing conducted during 1995-1996 Work Orders ,
REQUIREMENTS / CODES:
NP 8.1.3 Post Maintenance Testing APPLICABLE DOCL31ENTS:
INPO 87-028, EPRI NP-7213 NRC Insp. Manual 73756 Inservice Testing of Pumps and Valves 10CFR50.55a, GL 89-04, NUREG-1482, NRC Bulletin 88-04 i l
ORGANIZATIONS TO BE AUDITED: Maintenance, Operations, I&C, Engineering ORGANIZATIONS NOTIFIED: Maintenance, Operations, I&C, Engineering I
' ~'
- AUDIT TEAM: , ,
,, ,s
- N&')
- Ar 7 PREPARED BY:
," /2[9~7
" ' ' - Date
Surveillance No.: S-P-97
Subject:
Post Maintenance Testing Page 2 of 5 .
- CHECKLIST & RESULTS I 1
Work Orders will be randomly selected and reviewed for adequacy of Post Maintenance Testing (PMT). A 20% sample of Work Orders (WO) related to Probabilistic Safety ,
Assessment (PSA) safety significant systems has been selected. The WOs were selected using a computer based random number generator which was applied to the population of WOs for each system. (Attachment D, Processfor Randomly Selecting Work Orders, describes the selection process.)
If necessary, the sample size will be expanded based upon identided problems that imply wide- ]
ranging potential for problems related to PMT. !
t
- 1. Verify that PMT is performed during and/or upon completion of maintenance work i and that it demonstrates with a high degree of confidence that the deficiency reported l 4 has been repaired and that the system affected by the repair is left in an operable condition. (Ref. NP 8.1.3 sec. 4.4 & 6.1.2)
Results: Unsatisfactory Objective evidence:
A list of the Work Orders reviewed is found in Attachment C.
1 Reviews of individual Work Orders and accompanying test procedure records were documented on Form QAF-072. Issues identified as a result of those reviews include:
3 Quality Condition Reports, QCR 97-0002, -0008,0010 (see Attachment A), and 2 Observation, #5 and #7 (see Attachment B) 1 The review of the following records led to the identification of the above deficiencies:
d WO 9609074,9606761, IT-10 (dated 10/29/96 and 12/18/96), PBF-2059 for AF-4022 l
. WO 9510440, 9503978, 941095, 9411508, 9504991, 9505432.
WO 9511497, WO 9404661, WO 9501342
- 2. Verify that any operability testing (performed after maintenance) is either sufficient as
+ r '1 PMT,~or that it is supplemented with adW.:onal tering. (Ref. NP 8.1.3 sec. 6.2.1) l Results: Satisfactory Objective evidence:
Reviews of individual Work Orders and accompanying records were documented on Form QAF-072. Issues identified as a result of those reviews include:
1 Observation - #4 (see Attachment B)
. S P-97-01.
Page 3 of 5 ,
- 3. If testing is not performed or deferred, verify that Section XI relief requests exist and are complied with.
' Results: N/A' Objective evidence: .
i The audit team did not identify any instances where relief requests were needed due to deferral of testing; hence, there was no input to this checklist question. .
- 4. Verify that following the completion of work that involves components in the ASME Section XI program, appropriate groups are notified to ensure that requirements are met. (Ref. NP 8.1.3 sec. 6.2.3) )
- Operations is notified to verify that IST test requirements are accurately specified. :
J
- ISI is notified to verify that pre-service inspection requirements are met.
Results: N/A Objective evidence:
The audit team did not identify any instances requiring follow-up of ASME Section XI issues; hence, '.here was no input to this checklist question.
- 5. Wrify that appropriate testing methods and instrumentation are used to provide sufficient information for assessing equipment operability. (Refer to NUREG-1480 sec.
5.5 as suggested guidance on pump test instrument ranges and calibration) For I
example:
e Is testing performed at established reference values? ;
- Is instrumentation of sufficient accuracy and is it calibrated? ~
i Results: Satisfactory Objective evidence:
Reviews of individual Work Orders and accompanying records were documented on Form l QAF-072. Issues identified as a result.of those reviews include:
2 Observations, #6 and #9 (see Attachment B) i
- 6. Verify that at the completion of PMT, acceptability of the equipment is based on satisfactory completion of all PMT specified. (Ref. NP 8.1.3 sec. 6.2.9) {
- Tests specified in MWR, PM task sheet, or procedure. i e If PMT matrices are used, the responsible group annotates successful completion. i 1
Results: Unsatisfactory Objective evidence:
Reviews of individual Work Orders and accompanying records were documented on Form QAF-072. Issues identified as a result of those reviews include:
5 Quality Condition Reports, QCR 97-0005, -0009, -0007, -0013, -0006 (see Attachment A), and 3 Observations, #1, #2, and #3 (see Attachment B) i
. S-P-97-01 Page 4 of 5 The review of the following records led to the identification of the above deficiencies:
.(QCR 97-0005) WO 9507728 (Testing of AF-04019, AF-04021), and IT-10s (completed 3/18/95 and 10/24/95), and PBF-2059 (dated 10/26/95, and 3/21/95) ,
(QCR 97-0009) WOs 9510440,9411524,9609074,9509937,9602851,9607141, l 9601543, 9512279, 9511505, 9401897, 9507728, 9502272 l (QCR 97-0007) WO include 935581, 9503367, 9506993, 9500819, 9506589.
(QCR 97-0006) WO 9508940, 9512304, 9513097 'i In reviewing the data, poor linkage / referencing between Work Orders and testing I procedures were noted for various systems (noted in parenthesis); consequently, QCR 97- 1 009 was written. Examples found during the reviews include: I l
- (CC system) ICP which documents the performance of testing does not list the WG which specified the performance of the test.
e (SW system) Review of Work Orders found that there was no direct, cleu tie between WO 9510440 & IT-09A. IT-9A was done a month later and dia act specifically indicate the test was to satisfy PMT for WO.
e (AF system) The IT-10's documenting the testing of valves did not reference the related work order numbers, namely: WO 9401897, 9507728, 9511505, 9512279, 9501543, and 9607141.
e (AF system) When Operations uses 0-PC-008 Parts 1 & 2 for performing testing, there is no inclusion of the work order number on ti,e signed completed test j procedure. ]
- (IA system) No link to WO 9502272 on PC-45 part t.
- 7. Verify that if PMT is unsatisfactory, deficiencies are documented, corrected, and re-tested, as necessary. (Ref. NP 8.1.3 sec. 6.2.13 & 6.2.14) 1 Results: Unsatisfactory Objective evidence:
Reviews of individual W.ork Orders and accompanying records were documented on Form .
QAF-072. Issues identified as a result of those reviews include: l 2 Quality Condition Reports, QCR 97-0002, -0011 (see Attachment A), and 1 Observation, #8 (see Attachment B)
The review of the following records led to the identification of the above deficiencies:
WO 9513292, 9509984, 9512482, 9404661 ;
- 8. Verify that if testing is done at other than normal design conditions, precautions or limitations are complied with (e.g., low flow test conditions are sufficient to prevent pump damage.)
. . _ _ _ - __ . . ... . . . _. . ._. _ ~ .._ _ _ _ . .
t
. . s.p.97_ot.
Page 5 of 5 .,
Results: Unsatisfactory - ,
Objective evidence:
Reviews of individual Work Orders end accompanying records were documented on Form QAF-072. Issues identified as a resuit of those reviews include: I' 2 Quality Condition Reports, QCR 97-0002, -0012 (see Attachment A) l The review of the following records led to the identification of the above deficiencies-
)
WO 9609074,9606761, IT-10 (dated 10/29/96 and 12/18/96), PBF-2059 for AF-4022 I I
i e
M '
e
^
w _
hr.
Y
Att:chmtnt A QCRs e
~
QCR 97-0002 Operability Post-Test not performed as indicated A work order directed stem cleaning and lubrication of a safety-related gate valve. The required operability post-test was IT-10. The work order indicates the valve was stroke tested per the IT and the stroke test was satisfactory on 10/29/96. However, the record ,
copy of the IT performed on that date has a temporary change that deleted the stroking of the valve that was worked on. Hence, based on the data in the record, the valve was not ]
stroked as indicated in the work order. Also, the IT documentation did not state the IT was performed to satisfy PMT for the work order. (Note: The valve was subsequently stroked on 12/18/96 to satisfy PMT requirements for another work order. Plant conditions did not require the valve to be in service between 10/29/96 and the 12/18/96 test date.)
QCR 97-0005 - Failure to follow " continuous use" procedure requirements Several instances were found where the Duty Shift Supervisor signed the Work Order as having completed valve testing to IT-10, Test ofElectrical-Driven Auxiliary FeedPumps and Valves With Flow to Unit i Steam Generators (Quarterly), ' without opening the procedure. This is contrary to NP 1.1.4, Rev.1, Procedure Use and Adherence, Paragraph 3.6.1 which requires that each step in a " continuous use" procedure be read prior to !
I performing the step,'that each step be performed in the sequence given and when required, and that each step be signed as it is completed before proceeding to the next _!
l step. (The valve testing was documer.ted on a PBF 2059 and filed in the IT-10 closed file. This results in the Work Order not being associated with an opened IT-10. Step 3.1 ofIT-10 has provisions to document the reason for the PMT and a space to document the Work Order Number.)
QCR 97-0006 - Missing record copy of RMP 9333-1 -_
l Staff Services was unable to locate the record copy of RMP 9333-1, Instrument Air Compressor andIntercooler AnnualMaintenance, completed on or about 1/9/96. This document was requested as objective evidence of PMT performance. At least two WOs referred to RMP 9333-1 for additional details. Without this document, the details are ;
unknown (but evidence indicates that test was performed and had satisfactory results.)
- QCR 97-0007 - Poor documentation of what PMT was done and the results of PMT Specific post maintenance testing results were not clearly documented for several work orders. 'the work orders may identify what is to be tested, but in some cases do not provide a sign-off er other indication that the testing was completed, or whether the >
+, 2results were satisfactory. g QCR 97-0008 - Manual valves and one check valve not functionally tested following maintenance Post maintenance testing following maintenance on several valves did not include functional testing of the valves. Testing of valve functions such as cycling of valves, seat leakage tests, or flow verification was not consistently performed. Such testing would have been prudent, and is recommended by PMT matrices.
L
Attrchment A - QCRs (ctnt.)
Page 2 i
l QCR 97-0009 - No cross-referencing between WO and procedure Several plant procedures, particularly In-service Tests (IT), are used to fulfill PMT requirements for work orders. There is a block at the beginning of these procedures for recording the purpose for performing the test, including the work order number for which
~
the test provides PMT. These are routinely inaccurate, and often a procedure does not l reference all the work orders for which the test satisfies the PMT requirements. The concern is that the tester has no way of knowing what specifically he is testing for; l consequently, they cannot focus on the functions to be tested to meet PMT requirements.
. In one case, a procedure had a temporary change that eliminated the portion of the procedure that provided the PMT for a particular work order, and this was not noticed ]
during testing or during post testing reviews. j QCR 97-0010 - Potential for non-QA parts used on QA-scoped systems or components Several instances were found where no QAR number was recorded, or there was uncertainty whether QA parts were used on QA-scoped systems or components.
. A safety-related filter was changed in the G01 EDG. No QAR number was recorded for the replacement filter.
- A non-QA pump was placed in the gas turbine (OT), a QA-scoped system.
i . Non-QA tubing and valve were added to a QA-scoped system per the system engineer.
No concurrence from QAS Q-List personnel was obtained in the last two examples.
QCR 97-0011 -Inadequate PMT and corrective action on DG testing
. Oil accumulated in the air box drain in excess of the leakage allowed by procedure.
However, no notification of the DSS, an action specified in the procedure, was evident in the documentation.
. A start failure alarm was received when the south bank of air start motors failed to start; however, the procedure step asking if"Any Corrective Action was required" was checked as "NO" In addition, no reason was given in this work order as to why the test failed. A subsequent work WO replaced the south bank air motors with spares, and another verification test performed. The procedure attachment was completed for the initial WO to document the failure of the EDG south bank of air motors. ,
(
- During performance of the monthly EDG operability verification performed under WO 9509984, an alarm was received throughout the procedure (Fuel Oil Pressure High ). The EDG TS was completed and the diesel returned to service as SAT. No follow-up WO was performed to correct the alarm, or replace the fuel oil filter.
- During the performance of WO 9512482 to verify the operability of the EDG, a fuel I oil leak of one drop /see was observed (no location provided). In addition, the VSR2 relay required rework to correct spurious operation. The EDG was retumed to service as S AT. No WO was issued to fix the fuel oil leak. l I
I
<W si, 4 4 4 ,v.41,. 2 u _ m-aw w_a 4 -- m:m Attichment A SCRs(cant.)
Page 3
. During the performance of WO 9404661, a pump was removed, repaired, and then retumed to service. No vibration test was specified in the close-out for the WO. This pump (GT-503) continues to have high vibration levels in service (per the System
, Engineer); G-05 is a QA-Scoped piece of equipment.
. QCR 97-0012 - Acceptance criteria not adequately justified Examples were found where results of tests were outside existing criteria for acceptance, yet determined to be acceptable.
- Relays were found to be out-of-tolerance on the Gas Turbine, G-05, a QA-scoped ;
piece of equipment. Relays were left out-of-tolerance and a statement added to the calibration sheets by the system engineer stating that the as-left relay condition was satisfactory. No technical verification signature was provided, nor was a 50.59 safety
. evaluation performed.
. EDG monthly operability tests (TS-81,82,83,84) contain acceptance criteria along with the actual measured value for lube oil viscosity. For many of these operability procedures, the measured values fell outside (below) the acceptable range and yet i were determined to be satisfactory. In addition, when the acceptance criteria was l changed, no safety evaluation was evident for the revised acceptable range.
. QCR 97-0013- Traceability of PMT records is inadequate 10CFR50, Appendix B, Criterion XVII, Qual /ty Assurance Records, requires records to 4
be identifiable and retrievable. During the performance of this surveillance, QA found that ITs, ICPs, and PCs required by work orders are detached from the work orders and microfilmed separately. There is no traceability of the IT, ICP, or PC to the specific work order, or of the work order to the specific IT, ICP, or PC. Neither the work order number J nor any other unique means ofidentification is recorded on the IT, ICP, or PC to allow l 1 traceability between these documents and the related work orders. QA noted that there is 3
a space ' ITs for recording work order numbers; however, it is not used consistently.
Although ITs, ICPs, and PCs are readily. retrievable from the microfilm files maintained at PBNP, they are not specifically identifiable to a particular work package to verify that 2
they document the work prescribed by that work package. The reviewer can only make an assumption that certain ITs, ICPs, or PCs were related to specific work orders by the dates on which they were performed.
M
(
t i
Attachment B Observations
. Observation #1 - Control room instrument indications not recorded When I&C performs instrumentativn calibration, the instrument pre-test (as found) and . (
post-test (as left) data does not include documentation of the control room display ;
information. ;
Recommendation: The recording of the instrument indications in the control room be l included as part of the I&C pre- and post- calibration data. ;
Observation #2 - Pogr_gansigency in PMT documentation practices After reviewing many work orders (e.g.,9509985,9503978,9503293,9502769, and 9410495), it became apparent that no standard method for documenting the completion of -
PMT has been established. PMT has been documented in any combination of the following methods: sign-offin the work plan, described in the " Work Performed" section of the work order, described in the " Equipment Return to Service" section of the work order, indicated by initialing near the test on the PMT matrix, or by attaching the -
supporting documentation (such as Hydrostatic test forms) to the completed work order. ,
Also, the results of the completed PMT was not consistently documented on the work l
- rders. In some cases this has led to a lack of documentation of PMT performed.
Recommendation: Establish expectations for documenting the results of PMT in work orders.
I Observation #3 - Testine recommended in PMT matrices not consistently followed ,
Description:
PMT guidance is contained in several PBF matrices that recommend certain testing when performing specific work on various components. This guidance is similar to the guidance in Attachment A of NP 8.1.3. Often, the guidance that was recommended was used as a list to choose from, and the choices were typically less than all the recommended tests. After reviewing several hundred work orders, it became apparent that the choices for testing were typically the easier to perform. For instance, a matrix recommended a seat leakage test when a valve is repaired and the seating surfaces are worked. This recommendation was seldom accepted even when the problem description in the work order stated "the valve leaks by."
Recommendation: Establish expectations governing the use of" recommended" testing guidance.
Observation #4 - ORT-3 testing overused as basis of PMT Various work orders for the 4160V system reference ORT-3 gs part of, or the entire basis for the PMT associated with the work performed. In the past ORT-3 has been used as a catch all to verify adegate maintenance was performed. In some cases although testing
-in ORT-3 will verify the function of the component, it is not the best basis to show acceptability of the maintenance performed. This verification should be performed prior to the final functional testing done in ORT-3. It is a good practice to verify acceptance of actual work performed by use of a lower tier document / procedure, or within the
, original document / procedure, such as an ICP or work order work plans, vs. verification
Attachment B - Observations (cont.)
Page 2 during a larger plant evolution procedure. It is recommended that ORT-3 not be used as ,
basis for PMT and all PMT be accomplished through lower tier documents / procedures. l Observation #5 - Testing procedures not clearly referenced in WO or poorly written ,
l
- 1. Maintenance Instructions (MI) provided as part of a work package are not kept as quality records because they do not contain any signatures or documentary l information. The work order does not identify the MI revision being used; therefore, 1 it is not clear what instructions were provided to the work order by the MI. l
- 2. Testing procedures are poorly written. Examples are:
. ICPs do not consistently specify what the "as found" conditions should be or :
request documentation of the "as found" condition so that when work is ;
complete there is reference information against which as-found conditions can be compared.
- PC-9, Part I specifies " normal load / unload pressures" as 95/105 psig (steps 4.14.6,4.21.6,4.10, and 4.17); however, no tolerance is specified for the acceptance criteria. Other data requested within the PC-9 do not have acceptance cuteria noted, e.g., maximum flow rates (steps 4.10 and 4.17). i Basis: Documentation provided in work packages and test documentation related to ,
work orders is incomplete or insufficient to provide adequate information to evaluate j work performed or equipment status.
Recommendation: ,
- 1. Have individuals performing the work record the revision number of the Maintenance i Instruction used in performing the work. l
- 2. Include all necessary information for performing a function in the documents being i used to direct that function. f Observation #6 - 50.59 safety evaluation scretnine contains misleadine information j 50.59 safety evaluation screening attached to WO 9603297 (involving setpoint changes) contains misleading information since it is based on incomplete information. The 50.59 screening correctly states that the G-05 Gas Turbine is non-safety related and concludes !
that the setpoint changes have no adverse impact to plant safety. However, the safety i evaluation fails to mention the reliability needed for G-05 for Station Blackout (augmented QA program). The manufacturer's specified calibration tolerance for the gages is 0.1 PSI, a precision which is unobtainable for commercial grade instrumentation.
, 3 However, that degree of precision is not required for proper operation of G-05. Based upon this criteria, the 50.59 screening to relax tne setpoint tolerance is acceptable, but the statement (contained in the 50.59 screening) that G-05 is non-safety related does not communicate all relevant information. '
Recommendation: Consider revising the 50.59 to clarify all relevant censiderations.
l 1
~
t Attachment B - Observations (cont.) '
Page 3 Observation #7 - No calibration for controller (on non-SR but OA-scope euuipment) ,
A controller on the Gas Turbine was replaced under WO 9508693. No calibration record was found for the installation per discussion with an I&C planner. The controller was i
" field" adjusted and returned to service. The Gas Turbine was re-verified as being operable on the next monthly operability run. .
Recommendation: Consider performing and documenting calibrations.
Observation #8 - Failure of monthly TS on diesels not counted neainst reliability program Monthly Technical Specification (TS) tests are performed on the diesels. If the test fails
- or preventative maintenance is performed following startup of the test, the result is not counted as a failed start towards the reliability program. For example, the test starts, a ;
high alarm is received, a filter is changed, and the alarm resets. The reason for a reliability database is to verify that the piece of equipment being tested would have been 4 available for the time lapsed between tests, not to verify the unit is reliable for the next time period. Reasonable assurance is provided that the equipment will perform its '
intended function based upon the equipment starting from an as-found or as-left condition from the preceding time period. Based upon the handling of test results, the reliability data would be skewed high and not be a fair representation of diesel availability or performance. (Reference WO 9511497). l Recommendation: Re-evaluate the method used for determining reliability. :
i Observation #9 - Poor practices in enterine and exiting LCOs l In the WO 9513292 printout the statements written arcanisleading. The " Work l 2
Performed" section has a handwritten note that G02 was declared OOS, but the LCO entered into by procedure step 3.12 was cleared. Subsequent review of the procedure TS 82 for this work order in procedure step 4.50 was nel signed off(suggesting that the LCO was still in effect). Follow-up review of the re-test done by follow-up Work Order 9513418 has procedure step 3.12 signed off suggesting that the LCO was re-entered by the new verification test, which would not be appropriate if the south air bank motors
- were deficient, changed and then verified (subsequent to the work done on the initial WO). By the Tech Specs there was a time when the supporting equipment needed for declaring the diesel was not available; and the LCO should not have been exited during the time period of the repair and re-verification of operability. However, since the time 4 .
expired was still within the seven day LCO, there was no reportable violation in the WO l reviewed. From a technical standpoint there may be 'an omission ofinformation to allow the LCO procedure step to be signed off. This is an observation of the technical content within the reviewed procedure. The LCO may not have been exited as stated within the procedure.
Recommendation: Clarify how LCOs should be exited and documented to avoid a possible violation.
Attachm:nt C List of Work Orders Reviewed
- AFW CCW DG GT IA SW 4160 kV 1 9401387 925008 926192 8513392 9406840 913434 9406030 2 9501190 9410619 940060 8609387 9412088 913435 9409484 3 9502305 9500577 940590 9404661 9412150 933164 9500288 4 9502689 9501147 6505541 9500019 9500198 935581 9500757 5 9502699 9503256 9403430 9500236 9501025 940858 9501571 6 9503706 9504612 9409492 9501801 9501029 9404869 9502934 7 9503707 9507306 9412120 9503141 9501030 9408479 9502935 8 9505793 9508362 9412205 9503142 9502272 9410335 9504850 9 9506768 9508400 9500182 9503985 9504384 9410495 9505642 10 9507728 9509078 9500231 9504094 9504589 9410524 9507549 11 9509480 9509215 9500560 9504287 9505309 9410697 9507553 12 9509857 9509239 9500570 9504289 9505338 9411508 9507562 13 9509982 9509385 9500573 9505542 9505567 9411705 9508782 14 9509987 9509870 9500819 9506705 9506905 9412194 9509882 15 9510308 9511649 9501100 9506706 9607310 9500547 9509991 16 9511024 9511939 9501433 9507736 9507363 9500684 9509992 17 9511505 9512260 9501679 9508445 9507906 9500841 9509996 18 9511573 9512347 9502328 9508693 9508940 9500842 9510004 19 9512130 9512685 9502781 9509074 9510150 9500945 9510009 20 9512279 9601182 9502783 9509466 9511401 9500946 9510010 21 9512763 9601415 9503583 9510622 9511597 9501014 9510368 22 9600088 9602069 9503745 9511341 9511881 9501452 9510855 23 9600992 9603209 9503803 9511744 9512305 9501497 9512116 24 9601543 9605471 9504166 9512293 9512740 9502769 9600676 25 9602547 9606853 9504266 9600394 9515097 9503293 9603534 26 9603134 9607371 9504976 9600653 9513695 9503367 9605562 27 9603985 9608956 9505222 9600791 9600859 9503461 9605563 --
28 9604221 9609787 9505520 9601795 9602391 9503978 9606641 29 9605452 9610366 9505521 9602587 9602620 9504297 9608622 30 9607141 9611139 9505565 9603297 9603302 9504365 9609211 l
31 9607454 9611205 9505571 9604362 9604301 9504701 9611187 32 9608312 9611483 9505719 9604582 9604530 9504948 33 9609066 9611749 9506181 9605150 9605391 9504991 34 9609074 9612534 9506586 9606052 9605507 9505118 35 9609988 9612679 9506589 '9606617 9605549 9505432 36 9610184 9612815 9507120 9607083 9607119 9506094 37 9612198 9700375 9507156 9607212 9609803 9506901 38 9612271 9507187 9608227 9611680 9506993 39 9613252 9507781 M09599 ~~82. 9507274 40 9613253 9508066 9611081 9611951 9507399 41 9508067 9611894 9612832 9507470 42 9508070 9612996 9613273 9507583 43 9508280 9613017 9614016 9508363 44 9508695 9614192 9700032 9508853 45 9508771 9509512 46 9508924 9509662 Page1
AttachmInt C List of Work Orders Reviewed
- AFW CCW DG GT IA SW 4160 kV 47 9509336 9509718 48 9509475 9509885 49 9509478 9509936 50 9509984 9509937 51 9510147 9509982 52 9510213 9510440 53 9510217 9510448 54 9510873 9510638 55 9511119 9510987 56 9511168 9511220 57 9511288 9511982 58 9511335 9512266 i 59 9511407 9512935 60 9511771 9513066 61 9511956 9513241 l 62 9512482 9513280 1 63 9512511 9513312 64 9512544 9513562 65 9512630 9513613 66 9513292 9600951 67 9513484 9601035 68 9600106 9601269 69 9600347 9601271 70 9600756 9602342 71 9601120 9602775
- 72 9601331 9602846
- 73 9601385 9602851 9601598 9603459 l 74 75 9602120 9604739 76 9602145 9604827 77 9602653 9605477 78 9603494 9606339 79 9603721 9607000 4 80 9603831 9607989 81 9604274 9608157 82 9604359 9608193 83 9604365 9606352 84 9604377 9609074 95 9604451 p w- F09316 86 9605090 9609381 87 9605576 9609381 88 9606578 9609724 89 9607105 9609791 ,
90 9607545 9609865 91 9607815 9610181 92 9608237 9610356 Page 2
Attachm:nt C List of Work Orders Reviewed
- AFW CCW DG GT IA SW 4160 kV 93 9608519 9611041 94 9608528 9611045 95 9609018 9611097 96 9609546 9611907 97 9609698 9611957 98 9610066 9612415 99 9610629 9612465 100 9611230 9613401 101 9612043 9613731 102 9612045 9614135 103 9612295 9614270 104 9612370 9700487 105 9612507 106 9612806 107 9613431 108 9613631 109 9614078 4
h 2 Page 3
r Attachment D Process for Randomiv Selectine Work Orders
- 1. Determine the minimum number of Work Orders (WO) to be done for a system
- Count the number of(1995-1996) Work Orders on the list for a system
. Multiply that number times 20% and round up
- 2. Choose any row and column from the Random Number List (Fig. A)
- Write down which row and column you selected to start from .
- 3. Select the first Work Order for review (for a system)
. Note the first digit in the five digit set of random numbers (note: in some cases, the sets may consist ofless than five digits)
. Count down the same number as indicated by the first digit in the five number set, e.g., if the random number set is "24957" count down "2" such that: WO#1 is the first WO on the list of Work Orders, WO#2 - is the second ,
WO on the list - hence, the first one to review (since the digit was "2").
- 4. Select the second (and subsequent) Work Order by counting down from the last one done the same number as indicated by the second digit (and subsequent digits) in the five number set, e.g.,
e If the number set (selected above) was "24957" count down "4" starting with l the WO following the one just done, etc. (note: the WO following the one jt,t done would now be WO#1)
- 5. After exhausting the first set of digits, proceed to the next column in the same row
- 6. After exhausting the entire row of digits, go on to the row immediately following the onejust used. If the last row of digits was used, go to the beginning of the first (top) row.
- 7. If the count would cause you to go past the last WO listed, ;
e Go to count the top of the list and count it as the next sequential WO, e.g., if you need to count to the "fifth" WO and the last one is WO#3, count the WO at the top of the list as WO#4, etc.
.. Note: if the WO that you would stop at has already been reviewed, go to the next available un-reviewed WO. (Note: while counting, do nd exclude intermediate WO's that have been reviewed) d i i a
H. Koch . 3/lI/97
. e
a a, Fig. A Random Number List (Typical Example)
Row A B . C D E F G l H I J
~} ~~56547 ~37IO5'" ~33735~
~ ~
1 "8iE68~ 5312A [ 59532~ ~55756 ~5530'3 84122 1 ~ 35555~
2 4771 85729 66394 81003 58838 78280 53418 42100 90253 99454 3 40612 14431 50330 15253 24511 46829 64781 42102 10360 68836 4 76105 29725 54548 38001 32263 84562 61396 94269 40604 94622 5 51921 8507 69820 27203 82359 73351 10651 29649 4487 88093 6 39526 6194 52642 18776 26859 4975 86095 61660 85513 46577 7 11946 82840 440 47972 60333 57053 62493 69889 6268 86170 8 51816 42894 87535 9538 95781 95362 96939 61046 56990 25940 9 10693 75608 68041 _51925 85494 66920_
_82290_ _ 9_5798__ 57_7_79_ 7219_7 10 43385 47588 84169 53606 93967 , 77231 76984 88368 92210 17514._
11 7309 10721 17317 98584 23561 18221 29387 32449 7227 4545 12 12314 76001 33760 81390 53992 79491 63268 81433 81834 17753 13 60121 5667 84438 87562 74089 57217
~
78878 91248 70317 11935 14 73728 49983- 8923 63314 T 31266 "5U156 ~~5527~-~~648d7 ~ ~ U559 9 ~ ~28599 ~
15 63431 82992 87832 24036 82891 1188 98765 99736 29934 6299 16 92639 30546 18084 29662 32033 22065 91477 24365 15622 52812 17 23282 77666 81698 79311 36264 76471 91896 41103 1454 1656 l
18 52027 82564 86458 28315 5811 98760 90262 84727 27784 97522 19 48292 4404 63069 30953 _ 19514 _.6853_7_ 90076 _ 6_456_6_ _ 26_801_ 36871 20 31200 45847 92485 22915 78186, _ _ 90858 35369 80147 45996 55935_
21 40311 19016 81550 24812 9197 52358 60250 41594 23549 5392 22 33078 87871 8812 65540 92801 23289 82310 93305 75025 42781 23 42882 70909 22504 42485 72236 54354 77585 93088 43013 58419 24 39894 27606 40928 77014 82702 44186 63273 28743 2954 37013 25 79286 94941 38324 9419 30788 98985 32813 , 85293 l 84833 70170
CONDITION REPORT (QCR)
. QCR 97-0002 l!
STATUS: ' CLOSED UNIT: 0 SYSTEM: AF INITIATED: 01/30/97 CLOSED: 03/17/97 MSS #: ADMINISTRATOR:
INITIATOR: . . . . . . . . ISSUE MANAGER-MUMBER OF OPEN ACTIONS: 0 NUMBER OF CLOSED ACTIONS: 1 Operability Post-Test not' performed as indicated. l 1
DESCRIPTION:
Work Order 9609074 directed seem clganing and lubrication of AF-40.22.
The required Operability Post-Test is IT-10 per this work order. The work order indicates the valve was stroked per IT-10 and the stroke test >
was satisfactory on 10 The record copy of IT-1Q performed on 10/29/96 has a temocra/29/96.ry change that deletes the stroking of Af-4022.
From the daQa in thl", record copy it is apparent that,AF-4022 was not stroxed during this procedure. The IT documentation did not state the IT was performed to satisfy PMT for this work order.
This valve was stroked on 12/18/96 to satisfy PMT requirements for Work Order 9606761. Plant conditions did not require this valve to be in service since the 10/29/96 maintenance.
Significance: Operability Post-Test was not performed as indicated.
STATUS UPDATE:
j03/17/97 This issue is closed based on the discussion in action
! item #1.
! SCREENED'BY : DATE: 02/03/97 REGULATORY REPORTABLE.....( ?: N TS VIOLATION.............. )N 10 CFR 21................. J: N TS LCO.................... /: N OPERABILITY IMPACT PER TS.t( J: N JCO REQUIRED......... ....
SCAQ.....................,
J: NN MSS REVIEW............... J:N 1 -
J: N COMMITMENT................ ?: N SUPPORTING DETERMINATIONS:
This event is not a reportability or coerability goncern Technical Specifications or other regulatory commitments.per the FSAR,
REFERENCES:
WO 9609074 IT-10 PBF-2059 FOR A7-4022, 12/18/96 S-P-97-01 QCR 97-0009 TRENDING INFORMATION:
WHEN-~: FOURTH QUARTER OF 1996 NON-OUTAGE WHO :
WHY : AWAITING FURTHER EVALUATION TO DETERMINE ROOT CAUSE W H A'1" - : MECHANICAL VALVE RELATED SYSTEM: AUXILIARY FEEDWATER ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE
'l$' A,, ) of $ , .
ACTION ITEM STATUS REPORT PAGE 1 03/28/97
- ' Responsible-Person: _.
- -Trkid: QCR 97-0002 *' Urgency: DONE
- Action Number: 1
- Work Priority: -100
- e***************************
Activity Pending is: DONE
TITLE AND TASK DESCRIPTION------------------------------------------ .
Operability Post-Test not performed as indicated.
Evaluate the condition report per Attachment C of NP 5.3.1.
___. ----------------------------r------------------
- ****** Correct ion ******
Sour e Record:_ - /97
---DATES-01/30 *******
Eval Due:
Evaluation 05 01 97 Corr Act Due:
Comm tment: Orig CA Due:
Act$on Create: 02 12 97 Orig Eval Due: 03 01 97 a Action Closed: 03 17 97 Eval Done: 03 10 97 Corr Act Done:
PEOPLE--------------------------------------------------------------
Responsnble for Overall Action: MSV Responsnble'for Current Pending Activity: ,,,,
Mana Init ator:ger:
Icau Punc list Administrator:
UPDATE-----------------------------------------
(02 Changed Res From to ged Responsible Group:ponsible Chan/19/97 From (MT) Person:To (MSV).. 9 (02 Changed the Due Date from: 03/01/9'/ The to 05/01/97 original aue date is completely inappropriate.
The/27/97 item was ,
identifiedon,1/30 but an action item was reasonable time frame is about 2 months from date of receipt.
not created.until 2/12. A more l
~(03/04/97 ' Changed Responsible Person: From ' to ). This needs to be done ASAP. Please review the NP referenced to maxe sure you I follow the procedure. l (03/06/97 ) Passed to for acceptance of work.
(03/10/97 Passed to for Verification.
- 1. Operations lost the paper work and for instrokin Obtained procedure IT-10 that was performed 10-28-97 rev.g AF-4022.2 of the procedure it is stated to delete stroking AF-4022. I contacted x-6335, who made the changes to IT-10 to find out why this was cone, ne said AF-4022 was deleted because unit 2 was in steam generator replacement and that OPS l wanted to maintain an absence of water in the piping. I went to document l control to see if there was any paper work to support the stroking of AF- l 4022 on that data There was none to be found. I searched OPS control locs i for any related In. formation to AF-4022 on 10-28-97 or 10-29-97 and found" !
none. I spoke with x-6208 who keeps records for stroking
.valvesand he has no intormation either Upon reveiw of maintenance actions taken in support of WO 9609074 I can't l find any anomalies. The major concern has to do with weather AF-4622 was i stroked and if so, why was it done when the IT-10 procedure used had deleted that step. This concern should be taken up with Operations.
(03 ) PLA Closure of ! tem. this actio:. item is being closed,and Per/17/97 discussions with .
the carent record will also be closed with no further actions, The nature of._the t o' p r eevent v e ndescribed is unusual,hisIn t such occurrences. particular t case,and we pyrrently the have barriersdia reviews in place not provide adequate assurance, but the circumstances surrounding this case are unusual in that the procedure for the test was changed between the time the work package was issued with the PMT identified and the time the testing was performed. Also the operators and the post
. missed this l'act. Additional actions are not deemed necessary.reviewerskust OC 97-0009 describes a condition where the test procedure does not always cite.the work order for which the test is being performed. When this issue is resolved, a current' prevent missing testing requiy established rements in thisbarrier manner.will be strengthened to
- ACTION ITEMLSTATUS REPORT - PAGE: 2 t 03/28/97 ,
't I
- a 4-e---REFERENCES----------------------------------------------------------
WO 9609074 IT-10 PBF-2059 FOR AF-4022,'12/18/96S-P-97-01
!.QCR.97r0009
___.____--MISCELLANEOUS-----'---------------- ----------------------- --------
Originating Agency: System: AF- '
NRC Open Item Nuder:
NRC Status:
s Related Outagcci.
Engineering Work Type: None Specified i Person Hours: Original Estimate =
Current Estimate = i Actual. Hours = 12 i 5
s 4
1 1
4 1 l
l
)
f 4
f j
t 6
- s- ,
s t
)
4 es 1
- * .,. , _ = , -_ ....-. _ . _ _ , ,
CONDITION REPORT -(QCR) '
i rQCR 97-0005 STATUS: OPEN UNIT: 0 SYSTEM: XX INITIATED: 02/10/97 CLOSED:~~~
MSS #: ADMINISTRATOR: '
INITIATOR: .
ISSUE MANAGER:
NUMBER 0F OPEN ACTIONS: 1 NUMBER OF CLOSED ACTIONS: u Failure to follow " continuous use" procedure performance requirements of NP 1.1.4, Procedure Use and Adherence DESCRIPTION: Procedure Use and Adherence, Paragraph 3.6.1 defines NP 1.1.4, Rev. 1
" continuous use",as readi performing the.stepf perf.ng orming eaghstep each stepininthe the procedure sequence given priorand to when required, signing o each step as it is completed before proceeding to the next step.
Contrary to the above, during the review of Post Maintenance Testing, Stgrt-up issue Numher 15 their are several instances where the Duty Shift Su ervisor signed hhe Work Order as havina completed valve testing to IT-10 Test of Electrical-Driven Auxiliary Fsed Pumps and Valves With without cpening a Flow to nit 1 Steam Generators (Quarterly) crocedure. The valve testing was documented on a PBF 2059 and filed in This results in-the Work Order not being ahe IT-10 closed ssociated with an file.opened IT-10. Step 3.1 of IT-10 has provisions to
- tocument the reason bor the PMT and a space to document the Work Order '
Namber.
5 Significance: Failure to to follow procedure NP 1.1.4.
1
. Corrective Action: Discussed this item with the Operations In Service l Tesit Coordinator.
STATUS UPDATE: j SCREENED BY : DATE: 02/18/97 I REGULATORY REPCRTABLE..... ): N TS VIOLATION... . .........
TS LCO....................
N N
10 CFR 21................. J:N OPERABILITY IMPACT PER TS. p:N JCO REQUIRED... . ......... : N MSS REVIEW................ J:N SCAQ...................... : N OPERADILITY DETERMINATION. J: N COMMITMENT............ .. N SUPPORTING This issue DETERMINATIONS:
is not a reportability or operability concern.
REFERENCES:
S-P97-01, WO/PMT IT-10 TRENDING INFORMATION: !
WHEN : FIRST OUARTER OF 1997 NON-OWAGE WHO :
WHY : AWAITING FURTHER EVALUATION TO DETERMINE ROOT CAUSE WHAT -~
- PROCEDURAL PROBLEM
. PBNP ADMINISTRATION PROCEDURE SYSTEM: NOT SYSTEM RELATED ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE
~~~ ~
~~~~i~~~~~~idh~~~~~d5hiEh'iUELhkT5bb ~b3/bb/97 u n - u ,
,y I
m..
l ACTION ITEM STATUS REPORT PAGE 1 03/28/97
- Responsible Urgency: Person:
NOT DUE / IN CLOSEOUT
- Trkid: OCR 97-0005 1
- Work Priority: -100
- Action Number:
Activity Pending is: REVIEW EVALUATION
TITLE AND TASK DESCRIPTION------------------------------------------
Failure to follow " continuous use" procedure performance requirements of NP 1.1.4, Procedure Use.and Adherence Evaluate the condition using the guidange of NP 5.3.1 AQtachment D. If the evaluation cannot be completed within 30 days, submit a corrective action p.lan.
Sour e Record:----02/10 /97 ******* Evaluation03 ** *****
DATES---- 97
- Correction ******
Corr Act Due:
Comg tment: Eval Due:
Action Create: 02/19/97 Orig Eval Due: 03 97 Orig CA Due:
Action Closed: Eval Done: 03 97 Corr Act Done:
......_____ PEOPLE---------------------------------------------
Responsable for Overall Acti Qn: OPS Res onsnble fcnr Current Pending Activity: QV Iss 9 Manager: -
Ini lator:
Punchlist Administrator:
UPDATE--------------------------------------------------------------
~
(03/21/97 -) Passed to for Verification.
OM 4.2.2, Inservice Tests, step /.a.o govern the use of form PBF-2059.
l
7.3.3 states
"The equipment inservice test must be documented in one of the following two methods and forwarded to the Operations Office:
l a) Completed section(s) of Technical Specification or Inservice Test procedure used to test equipment.
b) Completed post-maintenance / inservice test form, PBF-2059, for the test performed (f or valve tests only. ) "
PBF-2059 states that the procedure should be used as a guide. " Stroke the
.above valve using the inservice test as a guide, with the duty shift superintendent's concurrence."
The guidance in the OM and on the PBF-2059 are adequate PMT controls for valves. The use of procedures as guides for valve stroking only, as governed by PBF-2059 is acceptable performance. CLOSED. ;
I
..--------REFERENCES----------------------------------------------------------
I
MISCELLANEOUS------------- --------
Originating Agency: System: XX :
NRC Open Item Number: NRC Status:
Related Outages: ;
Engineering Work Type: None,Specified Person Hours: Original Estimate =
Current Estimate =
Actual Hours =
v 1
L CONDITION REPORT (QCR)
QCR 97-0006 STATUS: OPEN UNIT: 0 SYSTEM: XX INITIATED: 02/07/47 CLOSED: l MSS #: ADMINISTRATOR:
INITIATOR: ISSUE MANAGER:
1 NUMBER OF CLOSED ACT1ond: 0 <
NUMBER OF OPEN ACTIONS:
Unable to locate record copy of RMP 9333-1 that was completed on 1/9/96 DESCRIPTION:
Staff Services was unable to locate the record copy of RMP 9333-3 completed on or about 1/9/96. This document was requested as obiective It is apparently lost.
evidence for the WO/PMT Surveillance, S-P-97-01.
RMP 9333-1, " Instrument Air compressor and Intercooler Annualon IA and document the work don Maintenance compressor k-2B" was used to directduringitsannualmaintenancegompletedif9/96onWO seven and(7) 9512304. AdditionallyWOs 9508940 other corrective maintenance WOs were done as well. 9513097 were selected for evaluation during the WO/Pt1T Surveillance to verify the adequacy and '
appropriateness of PMT. Both referred to WO 9512304 to see details on RMP 9333-1. Without this document theae details are unknown.
QA document and record existance and retrievability are required.by the '
nuclear QA Program.
Corrective Actions: A thorough searchwas done of the appropriate record files and each of the 8 associated WOs for possible attachment with no success. <
STATUS UPDATE:
SCREENED BY : ' DATE: 02/12/97 : N !
REGULATORY REPORTABLE..... : N TS VIOLATION...... .... ..
- N TS LCO........ ........... : N 10 CFR 21................. : N OPERABILITY IMPACT PER TS. : N JCO REQUIRED.. ........... <
l
- N SCAQ...................... : N MSS REVIEW.,.............. COMMITMENT. N j OPERABILITY DETERMINATION. : N . ............
l SUPPORTING DETERMINATIONS: I This issue is not a reportability or operability concern.
REFERENCES:
RMP 933-1 (1/9/96) WO 9508940 WO 9513097 S-P-97-01 RMP 9333-1(1/9/96)
TRENDING INFORMATION:
WHEN-- : FIRST QUARTER OF 1997 NON-OUTAGE WHO :
WHY : AWAITING FURTHER EVALUATION TO DETERMINE ROOT CAUSE l
WHAT- : MAINTENANCE PROCEDURE EQUIPMENT RELATED QA WORK MONITORING RELATED SYSTEM: INSTRUMENT AIR ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE
~~~~i~~~~~~ih6~~~~~EhkLbkhIbh bbbbbb b423b 97~
l
ACTION ITEM STATUS REPORT PAGE 1 03/28/97
- Responsible Person:
- Trkid: QCR 97-0006
- Urgency: vun IN 31-60 UMId Action Number: 1
- Work Priority: -100 Activity Pending is: EVALUATION NEEDED
TITLE AND TASK DESCRIPTION---------------------------------------
Unable to locate record _ copy of RMP 9333-1 that was completed on 1/9/96 Evaluate the condition identified on the parent record for generic
. concerns in accordance with Attachment D of NP 5.3.1.
Recommen ation: Initiate a more extensive search for document RMP 9333-1(1 9/96) or find another means to recreate or reproduce the informat on and results so that the QA records can be completed and up-to-date.
02 -------------------------------------------------- ion ******
Sour e Record:-----DATES- ******* Evaluation ********* ****** Correct
/07/97 Comm tment: Eval Due: 04/30/97 Corr Act Due:
Orig CA Due:
Action Create: 02/13/97 Orig Eval Due: 03/12/97 Action Closed: Eval Done: Corr Act Done: ,
.________. PEOPLE----------------------------------
Responsible-for Overall Action: MSV Responsible for Current Pending Activity: MSV Issue Manager: --
Initiator:
Punchlist Administrator:
__.______-UPDATE------------- ------------------------------------------------ ,
1 (02/14/97 Changed Responsible Person: From ,_ to . l 1996 and 1997 microfilm legs has been '
(02/14 comple/97 i RMP 9333-1, completed 1/,9 was not received by NIFi for l 4 ted, mi rofilming.
A verification of the/96, ion I recommend that this act item be assigned to i Ma ntenance to search for the document or recreate the inforr* --
(02 Ghanged Res From to ged Responsible Group:ponsible Chan/17/97 Person:
From (SSV) To (MFS).
Changed Responsible section: From (NOS) To (MT)..
Changed Res (02 ged Responsible Group:ponsible Person: From to Chan/28/97 From (MFS) To (MSV)..
(03 Changed Responsible Person: From o_ i to . This is !
shor/10/97 t notice,L_mbut, we need to di something in the next few days. l (03/13/97 Changed the Due Date from: 03/12/97 to 04/30/97
REFERENCES----------------------------------------------------------
RMP 9333-1(1/9/96) WO 9508940 WO 9513097 S-P-97-01
MISCELLANEOUS---------------------- --------------------------------
Originating Agency: 3 stem: XX NRC Open Item Number: N C Status:
- Related Qutages:
Engineering Work Type: None,Specified Person Hours: Original Estimate =
Current Estimate =
Actual Hours =
' CONDITION REPORT'(QCR)-
QCR 97-0007 .
s STATUS: OPEN UNIT: 0 ' SYSTEM:-XX INITIATED: 02/11/97 CLOSED:
MSS #: ADMINISTRATOR:
INITIATORt . .. . mmdN ISSUE MANAGER:
NUMBER OF CLOSED ACTIONS: 0
' NUMBER OF OPEN ACTIONS: 1 ,
~ Post Maintenance Testing Results Were Not Documented For Several Work Orders DESCRIPTION PostmaIntenance testing resulQs were no' documented for sevgral work orders. The. work order identifies what it to be tested but-in some
.ases.there,1s no signoff-or other indication the testin,g was completed,. ;
or whether it was saEisfactory. The affected work orders include 935581, 9503367, 9500819, 9506589. j Significance: Unable to determine what testing was performed and ,
whether the testing results are satisfactory.
' STATUS UPDATE: ,
SCREENED BY : . . . . . _ _ . . _ . _ DATE: 02/13/97 :N
- REGULATORY REPORTABLE..... : N TS VIOLATION. ............] *
- N TS LCO.................... ; : N 10 CFR 21................. : N
- OPERABILITY IMPACT PER TS. : N JCO REQUIRED.............. L MSS, REVIEW................ -
N SCAQ...................... ( : N
- N COMMITMENT................L : N
SUPPORTING DETERMINATIONS: Safety related equi This is an administrative concern. ,
directly affected. This is.not considere6 reportable. pment was not ,
REFERENCES:
WOS 935581, 9503367, 9506993 S-P-97-01 9500819, 9506589 TRENDING INFORMATION:
WHEN--: NON-OUTAGE 1990 - 1999 WHO : MECH AND ELEC MAINTENANCE WHY : ACCOUNTABILITY OR RESPONSIBILITY WAS LESS THAN ADEQUATE
'WHAT : MAINTENANCE PROCEDURE SYSTEM: NOT SYSTEM RELATED ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE
~
~~~~{~~~~~.id6~~~~~dEU{Eh"Eh5LU hj6h~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~b4/3b/97
.v w e v ,~ -- , c --
1 ACTION ITEM STATUS REPORT .PAGE l' 03/28/97
"******************************* Responsible Person:
- Trkid: OCR 97-0007
- Urgency: Nur DUE / IN ULOSEOUT
- Action Number: 1
- Work Priority: -100
. l Activity Pending is: . REVIEW EVALUATION
TITLE AND TASK DESCRIPTION---- -'-----------------------------------
Post Maintenance Testing Results Were Not Documented For Several Work Orders Evaluate this QCR per the guidance of NP 5.3.1 Attacment C.
Sour e Record:----02/11 /97 ******* Evaluation04***
DATES---- ***** ****** Correction ******
Comm tment: Eval Due: .
30 97 ~ Corr Act Due:
Action Create: 03/04/97 Orig Eval Due: 03 13 97 Orig CA Due:
Action Closed: Eval Done: 03 25 97 Corr Act Done:
PEOPLE--------------------------------------------------------------
Responsible for Overall Action: MSV 3 Res onsible for Current Pending Activity: QV Ise e Manager: 1 :
Ini iator: l Punchlist Administrator: 1
..-.------UPDATE-------------------------------------------------------------- 1 (03/08/97 ?) Changed the Due Date from: 03/13/97 to 04/30/97
-(03/08/97 Qhanged Res From _.) to - _;
Changed Responsible Group:ponsible From (MT) Person: To (MSV)..
to l (03/10/97 Changed Responsible Person: From .
(03 The work Orders referenced in this QCR were all processed Drio/24/97r to revision 4revision which is Bated 1/24/97. Thisof Procedure NP8.1.1 has strength (work ened Order the requirements Processing)for Post i Maintenance and Return to Service testing. l Prior to the work being performed form PBF-2114 Return to Service
'TestingReviews is filled out by the Work Group, doerations IST, En ineering and Section XI engineering to show the testing, requirements.
Af er the wo,rk is performed, these departmenqs again review Revisions the form toin 1 al ow any updating necessitated by changes in work scope.
paragraph 6.14.16 require that the worker perform and document PMT.
Revisions in paragraph 6.15.5 require that the First Line Supervisor verify the adequacy and document the performance of the PMT Engineering '
the WCC,he out in t revisions to 6.16,the DSS 17, 18, and and theGroup19. Head have similar responribilities spelled l .
It appears that the long term changes to Post Maintenance and Return to Service Testing sought by this QCR have already been nrovided by the procedure revision and accompanying culture change. This QCR should be closed.
(03/24/97 ., Passed to for acceptance of work.
-(03/25/97 3) Passed to for Verification.
see update section
- IE F E R EN C E S - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
S-P-97-01 WOS 935581, 9503367, 9506993 9500819, 9506589
MISCELLANEOUS----------------+----- --------------------------------
Originating Agency: System: XX NRC Open Item Nuder: NRC Status:
Related Outages: +
' Engineering Work Type: None Specified Person Hours: Original EsQimate =
Current Estimate =
Actual Hours =
CONDITION RBPORT (QCR) )'
-QCR 97-0008
" STATUS: OPEN UNIT: 0- SYSTEM: 2O( INITIATED: 02/11/97 CLOSED: 'i MSS #: ADMINISTRATOR: - - "4 ISSUE MANAGER: :
INITIATOR: . ... ..
0
' NUMBER OF OPEN ACTIONS: 1 NUMBER OF CLOSED-ACTIONS: 1 Functional Testing Not Included in Post Maintenance Testing DESCRIPTION PostmaIntenancetesting.for'severalvalvesworkedunderseveralwork orders did not include functional testing of the valves. Tests omitted included cycling of valves -seat leakahetests,941095, or flow verification.
Affected work orders include 9510440, 503978, 9411508, 9504991, 9505432, and 9602775. J 1
Significance: Valves were not verified to be.able to perform'their j intended functions following maintenance.
l S'L4TUS UPDATE: 1 SCREENED BY : DATE: 02/13/97 REGULATORY REPORTABLE..... ?: N TS VIOLATION.............. ): N 10 CFR 21................. p: N TS LCO.................... p : N l OPERABILITY IMPACT PER TS, p: N .JCO REQUIRED........ ..... J . N ]
MSS REVIEW................ J: N SCAQ................. ....
COMMITMENT................
p : N J: N i
1 OPERABILITY DETERMINATION. J: N i
SUPPORTING DETERMINATIONS. ,
Only two of the WOs are considered safety related equipment. Both of l the safety related valve work orders were.PM. The FMs state that.the !
valves were to Derform to a criteria as stated in the WO. At this time l it is not consiBered to degrade the performance of the equipment. This i is not reportable.
REFERENCES:
WOS 9510440, 9503978, 941095, S-P-97-01 9404991, 9505432 1
TRENDING INFORMATION:
WHEN-- : 1990 - 1999 NON-OUTAGE
'WHO
- MECH AND ELEC MAINTENANCE POLICIES, OR ADMIN CONTROLS (SPAC)
WHY : INADEQUATE STANDARDS WHAT- : MAINTENANCE PROCEDUR$
MECHANICAL VALVE RELATED SYSTEM: NOT SYSTEM RELATED ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE ,
~
'~~~~i"~~~~~i66~~~~~6ydL6Eti66~655656~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~64J3bf97~
i h p t
+
ACTION ITEM STATUS REPORT PAGE 1 03/28/97 ee***************************** Responsible Person: _ . . . . _ .
- Trkid: OCR'97-0008
- Urcency: vus IN 31-60 DAYS
- Action Number:
1
- Work Pri6rity: -100 Activity.Pending is: EVALUATION NEEDED
TITLE AND TASK DESCRIPTION------------ -------------------- --------
Functional Testing Not Included in Post Maintenance Testing Evaluate this QCR per the guidance of NP 5.3.1, Attachment C.
DATES-------------------- ------------------------------------------ ********* ****** Correction ******
Sourge Record: 02/11/97 ******* Eva Commitment: Eval Due: luation /30/97 04 Corr Act Due:
Action Create: 03/04/97 Orig Eval Due: 03/13/97 Orig CA Due:
Action Closed: Eval Done: Corr Act Done:
......__.. PEOPLE--------------------------------------------------------------
Responsible for Overall Action: MSV Responsible for Current Pending Activity: MSV Issu Mana Init ator:ger: -
Punc list Administrator:
- - - - - - - - - - U P DAT E - - - - - - - - - - - - - - - - - - - -
(03/08/97 ') Changed the Due Date t.om: 03/13/97 to 04/30/97 (03/08/97Responsible Ghanged Res From ') to 8
-Changed Group:ponsible From (.MT) Person:
To (MSV)..
(03/10/97 Changed Responsible Person: From i to
_...____.-REFERENCES--------------------- --
-S-P-97-01 WOS 9510440, 9503978, 941095, 9404991, 9505432
..... .--. MISCELLANEOUS---------------------- --------------------------------
Originating Agency: S stem: XX NRC Open Item Number: N C Status.
Related Outages:
Engineering work Type: None,Specified Person Hours: Original Estimate ==
Current Estimate Actual Hours =
CONDITION REPORT (QCR)
QCR 97-0009 i
STATUS: OPEN UNIT: 0 SYSTEM: XX INITIATED: 02/11/97 CLOSED: )
. MSS #: ADMINISTRATOR: i INITIATOR: ISSUE MANAGER: ..
WUMBER OF OPEN ACTIONS: 1 NUMBER OF CLOSED ACTIONS: 0 PMT Testing Requirement Not Always Communicated in_ Supporting Procedures DESCRIPTION:
Several plant procedures particularly ITs are used to fulfill PMT requirements for work orders. There is a block at f the i beginning of
-these procedures for recording the purpose for per orm ng the testthese including the work order number for which the test provides PMT.
are routinely inaccurate and often a procedure does not reference all the work orders.for which the test satisfies the PMT requirements.
Sign ficance: The tester has no way of knowing what specifically he is i test no-for PMT, and conse focus on the tunctions ,
requ ring test:.ng for PMT.quently cannot In one case a procedure had a temporarv l change tItat eliminated the portion of the procedure that provided the PMT ror a particular work order, and this was not noticed during testing or during post testing reviews.
STATUS UPDATE:
SCREENED BY : DATE: 02/13/97 REGULATORY REPORTABLE..... : N
- N TS VIOLATION..............{
TS LCO...................
N N >
10 CFR 21................. : N I OPERABILITY IMPACT PER TS. . N JCO REQUIRED..............
MSS REVIEW................ : N SCAO...................... : N OPERABILITY DETERMINATION. : N- COM I TMENT . . . . . . . . . . . . . . . . : N
. SUPPORTI G DETERMINATIONS At t is time operabil ty of safgty related is noQ considered degraded.
This concern aadresses the continunity of communication between supporting procedures. This is not considered a reportable issue.
REFERENCES:
9411524, 9609074 S-P-97-01 WO 9510440 9602851, 9607141, 9601543, 9512279, 9S11505, 9401897 9507728, 9502272 TRENDING INFORMATION:
WHEN : 1990 - 1999
-- l NON-OUTAGE 1
'WHO :
i WHY : INADEQUATE ENFORCEMENT OF ADMINISTRATIVE CONTROLS (SPAC) !
WHAT~ : MAINTENANCE PROCEDURE OPERATIONS PROCEDURE SYSTEM: NOT SYSTEM RELATED ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE l 4 ~~~~i-~~~~~iB5~~~~~s9EE6ifi6~~69EiB6i~ ~~~~~~~~~~~ ~~~~~~~~~~~~~~~~53?is?~7~
i a
I l
ACTION ITEM STATUS REPORT PAGE 1 03/28/97 i
- Responsible Person:
- Trk$d: OCR 97-0009
- Urgency: PAST DUE 1-30 DAYS Action Number: 1
- Work Priority: -100 l 1
Activity Pending is: EVALUATION OVERDUE l
--TITLE AND TASK DESCRIPTION----- ------------------------------------ l PMT Testing Requirement Not Always Communicated in Supporting Procedures ,
l Evaluate this condition per guidance of NP 5.3.1, Attachment C. ;
1 I
.-----DATES-------------------- --------------- --------------------------
- ****** Correction ******
Sourge Record: 02/11/97 ******* Eva l Commitment: Eval Due: luation03/13/97 Copr Act Due: !
Act:.on Create: 03/04/97 Orig Eval Due: 03/13/97 Orig CA Due: l Act;.on Closed: Eval Done: Corr Act Done. ;
1
PEOPLE-------------- -------------- - ------------------------------ ;
~~~
Responsible for Overall Actign: OPS Responsible for Current Pending Activity: OPS '""
Issu9 Mana Initiator:ger: n Punchlist Administrator:
_---------UPDATE-------------------------------------------------------~~-----
REFERENCES-------------------------- -------------------------------
S-P-97-01 WO 9510440 94115 24, 9609074 j 9602851, 9607141, 9601543, 9512279, 9$11505, 9401897 ;
-9507728, 9502272 ;
--.-------MISCELLANEOUS---------------------
Ori;ginating Agency: S hstem: XX NRC Open Item Number: NRC Status:
Related Outages:
Engineering Work Type: None,Specified Person Hours: Original Estimate =
Current Estimate =
Actual Hours =
i
- , - , n e .c i
i
CONDITION REPORT (QCR) c QCR 97-0010 t s
STATUS: OPEN UNIT: O SYSTEM: XX INITIATED: 02/11/97 CLOSED:
~~~~"K MSS #: ADMINISTRATOR: .
~
TNITIATOR: .-_.m_.'. ISSUE MANAGER: .
NUMBER OF OPEN ACTIONS: 2 NUMBER OF CLOSED ACTIONS: 2 Non-QA parts used in QA scoped system DESCRZPTION-
- 1. During performance of WO 9511497, a filter was changed in the G-01 EDG. No QAR number was recorded for the replancement filter. This was a safety related filter change out.
- 2. During the performance of WO 9404661, a non-QA pump was placed in a No concurrence from QAS or Q-List personnel was OA Scoped System (GT .
obta:.ned System Engineer stated in WO that non-QA parts were not requ:. red.to be used in the work order.
- 3. During-performance of WO 9503142 non-QA parts (i.e. tubing-and valve) were added to a QA scoped sysbem per system engineer. No QAS of Q-List approval was obtained Significance:
- 1. QA scoped cauipment and QA scoped work order does not have required information to determine of corect part was installed.
1
- 2. .Non-QA pump installed in QA application without proper documentation or-approvals.
- 3. Non-QA tubing and valve added to QA scoped system.
STATUS UPDATE:
SCREENED BY : ~. ..N DATE: 02/17/97
?: N REGULATORY REPORTABLE..... ?: N TS VIOLATION.............. (
TS LCO.................... (
10 CFR 21................. J:N JCO REQUIRED.............. (
/: N-N OPERABILITY IMPACT PER TS. ': N 0 MSS REVIEW................ ): N SCAQ......................( /:N OPERABILITY DETERMINATION. J N COMMITMENT..... ..........t J: N SUPPORTING DETERMINATIONS:
Does not appear to be a reportability or operability concern at this time.
REFERENCES:
WORK ORDER : 9511497 WORK ORDER #9501342 WORK ORDER : 9404661 TRENDING INFORMATION:
WHEN ~~
- FIRST QUARTER OF 1997 NON-OUTAGE WHO :
WHY : UALITY CONTROL WAS LESS THAN ADEQUATE WHAT --
- A RELATED A WORK MONITORING RELATED SYSTEM: OT SYSTEM RELATED ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE 2 -100 DONE 03 97 3 -100 REVIEW EVALUATION - c 03 97 4 ^ -100 . EVALUATION NEEDED _
04 97
^
..a....... ........................... ...s. ...............................
- - ~ -
ACTION ITEM STATUS REPORT PAGC 1
" 03728/97 c****************************** Responsible Person:
- Urgency: DONE
- Trk{d: OCR 97-0010 Action Number: 1 *- Work Priority: -100 I
-Activity Pending is: DONE
TITLE AND TASK DESCRIPTION------------------------------------------ ;
Non-QA parts used in QA scoped system Evaluate Quality condition report. This item was noted-during U2 start-up j issue #15, PMT. j i
-----DATES--
Sour e Record: 02/11/97 ******* Evaluation ******** ****** Correction ****** i Comm tment: Eval Due: 03 10 97 Corr Act Due: l Action Create 02/26/97 Oriq Eval Due: 03 10 97 Orig CA Due: l' Action Closed:: 02/27/97 Eval Done: 02 27 97 Corr Act Done:
i
____. .---PEOPLE-------------------------------------------------------------- 1
~
Respons:.ble for Overall Actign: NMS f i Respons:.ble for Current Pending Activity: l Issu9 Manager: --'*""
Initiator:
Punchlist Administrator:
UPDATE-- -------------------------------------------- --------------
(02/27/97 PLA Closure of Item.
dUE TO INPUT ERROR THIS ACTION IS CLOSED TC ACTION ITEM #4
. .....___ REFERENCES---------------------------------------------------------- )
WORK ORDER #9511497 WORK ORDER #9501342 WORK ORDER #9404661 l
........--MISCELLANEOUS---------------------- ---------------- ---------------
Originating Agency: S stem: XX NRC Open Item Number: N C Status !
Related Outages: U2R22 Engineering Work Type: None Specified l
~
Person Hours: Original Estimate =
Current Estimate =
Actual Hours =
l i
i l
l
'I
-ACTION-ITEM STATUS REPORT PAGE 1 03/28/97
- Responsible Person:
- Trkid: OCR 97-0010
- Urgency: DONE
- Action Number: 2 :* Work Priority: -100 !
- j Activity Pending is: DONE
TITLE AND TASK DESCRIPTION------------------------------------------
G-01 EDG Filter-replacement - No QAR recordered l l
-Noted during Start-up Issue #15, PMT. Recording of QAR # will close item l
- 1on this QC.
- ***** ****** Correction ******
Source Record:---------DATES-02 /11/97 Evaluation 97 Corr Act Due:
1 Commitment: Eval Due: 03 <
Act4cn Create: 02 27 97 Orig Eval Due: 03 97 Orig CA Due:
Action Closed: 02 27 97 Eval Done: 02 97 Corr Act Done:
.......... PEOPLE--------------------------------------------------------------
Responsible for Overall Action: BMS Responsible for Current Pending Activity: ~~ - ~ ~ - ~ ~ ' '
Issue Mana
-Initiator:ger: ,
(
Punchlist Administrator:
UPDATE-------------------------------------------------------------- l (02/27/97 JJP) PLA Closure of Item. l DUE TO INPUT ERROR THIS ITEM IS CLOSED TO ACTION ITEM #4. i 1
i j
.......... REFERENCES----------------------------------------------------------
I
....------MISCELLANEOUS---------------------- ---- ---------------------------
Originating Agency: System: XX i NRC Open Item Number: NRC Status:
Ralated Outages:
Engineering Work Type: None,Specified Person Hours: Original Estimate = j Current Estimate = i Actual Hours =
I 1
]
j i
i NN
ACTION ITEM STATUS REPORT PAGE 1 03/28/97
- Responsible Person:
- Trk4d: OCR 97-0010 Urgency: NOT DUE /. IN CLOSEOUT Action Number: 3
- Work Priority: -100 Activity Pending is: REVIEW EVALUATION
TITLE AND. TASK DESCRIPTION------------------------------------------ ;
Non-QA parts used in QA scoped system Items 2 + 3 identified in start-up issue #15, PMT. Suggested resolution would be work with QA Q-list personnel to resolve the parts issues.
02 -------------------------------------------
Source Record:....__.---DATES- /11/97 Evaluation ** ***** ******
- ------ ion ******
Correct 1 Commitment: Eval Due: 03 19 97 Corr Act Due:
Orig Eval Due: 03 10 97 Orig CA Due:
Act4cn Create: 02/27/97 Action Closed: Eval Done: 03 18 97 Corr Act Done:
___.....__ PEOPLE----------------------------------
Responsable for Overal) Actign: EIS '" "
Responsnble for Current Pending Activity: QV i i
Issue Manager: '
Initiator: "~
Punchlist Administrator-
.... ....-UPDATE-------------------------------------------------------------- l (03/10/97 Requested Due Date: 04/15/97
'(03/10/97 Changed the Due Date from: 03/10/97 to 03/19 to higher Request due date change. Unable to support current date due/97 l
priority work. .
(03/12/97 Passed to ' for acceptance of work.
(03/18/97 Passed to ._.. . . . _ . for Verification.
WO 9503142 provided a blowdown valve on the instrument air supply line to the G-05 Glycol Cooler Louver Actuator. This blowdown valve is normally and is installed on a regulated (20 psig) air supply closed
-line. and Thecapoed,is valve a standard brass Whitey valve which .is used in numerous applications at PBNP, and was installed on a copper air supply installation, in
-line. The valve assembl addition to being capped.y was leak checked following the service and engineerin Based on judgment, the required pressure rating, material,the valve does not need to be replaced or dedicated in place.g The responsible enaineer did not understand the scope of the Augmented Quality requiremenEs for this apolication and He assumed that a non OA valve has since discussed this would be appropriate in this application.
situation with a QA representative to clarify the scoping of G-05.
The gomponent has been shown to be capable of providing its augmented quality function and the QCR documents that fact. This item may be closed.
REFERENCES------------------------------
....__...-MISCELLANEOUS----------------------
S stem:. XX Originating NRC Open Item Agency:r:
Numbe * 'N C StaCus:
Related utages:
-Engineer ng hork Type:l Person Hours: Estimate =None,Specified Origina Current Estimate =
Actual Hours =
' ACTION ITEM STATUS REPORT PAGE 1 03/28/97
- Responsible Person: _ _ , _ _ .DUE IN 31-60 DAYS
- Trk$d:
OCR 97-0010
- Urgency:
Action Number: 4 .
- Work Priority: -100 Activity Pending is: EVALUATION NEEDED
TITLE AND TASK DESCRIPTION------------------------------------------
Non-QA parts used in QA scoped system Record QAR numbers as necessary for filter change.
DATES------------------ ------- -----------------------------------
Sourge Record: 02/11/97 ******* Eva ********* ****** Correction ******
Commitment: - luation /30/97 Eval Due: 04 Corr Act Due:
Action Create: 02/27/97 Orig Eval Due: 03/10/97 Eval Done:
Orig CA Due:
Corr Act Done:
Action Closed:
<._________ PEOPLE---------------------- --------------- -----------------------
Responsible for Overall Action: MSV Responsible for Current Pending Activity: MSV ,
Initiator:ger:
Ispue Mana -.
Punchlist Administrator:
UPDATE--------------------------------------------------------------
(03 /08/97 .._. , Changed the Due Date from: 03/10/97 to 04/30/97 (03 Ghanged Res From , _ _ to ged Responsible Group:ponsible
.Chan/08/97 Person:
From (;MT) To (MSV)..
(03/10/97 Changed Responsible Person: From to .
(03/28/97 ...__) Passed to 1 i for acceptance of work.
REFERENCES--------------------
WORK ORDER 9511497 WORK ORDER # 9501342 WORK ORDER 9404667
___--___--MISCELLANEOUS---- -----------------
Originating Agency: S stem: XX NRC Open Item Number: N C Status:
Related Outages:
Engineer'ag Work Type: None,Specified Person i.aurs : Original Estimate =
Current Estimate =
Actual Hours = 12 g- 1 . -
! CONDITION REPORT (QCR) .
l QCR 97-0011 i
l STATUS: OPEN- ' UNIT: 0 SYSTEM: DG INITIATED: 02/11/97 CLOSED:
EMSS #: ADMINISTRATOR:
l INITIATOR: . c ISSUE MANAGER: i jiNUMBER OF OPEN ACTIONS: 1 NUMBER OF CLOSED ACTIONS: 2 l Inadequate DSS notification and documentation of EDG problems DESCRIPTION:
- 1. Per Work Order 9513292, oil accumulated in the air box drain in excess of 250 ml as d 9tailed following Procedure Step 4.49. Per Progedure Step 4,40, if >250 ml of oil is accumualtated in the air box dralny, the DSS-la to be notified per Procqdure notification of the DSS is mentioned in this procedure.
Step 2.6.2.b. No
- 2. During performance of Work Order 9513292, a start failure alarm was received due to the south bank of air start motors failing. Procedure
. Step 5 3 ("Any Gorrective Action Reg'd?) was checked as "NO". No reason
! was given in this work order as to why this test failed. Sequential work orders replaced the soutn No bandk air motorswith spares and another failure Attachment was completed for verification test performed.
the initial work order to document the failure of the EDG south bank of air motors.
- 3. During performance of the monthly EDG operability veri fication performed under Work Order 9509984, an alarm was received throughout the procedure (Fuel Oil Pressure High). No follow-up was performed to The EDG TS was completed and the
-diesel returned to service as SAT.
correct the alarm or replace the fuel oil filter.
- 4. During th performance of Work Order 95124382 to verify the operability o the EDG, a fuel oil the leak of 1 drop /sec was observed (no VSR2 relay required rework to location prov ded). In addition,EDG was returned to service as SAT. No correct-spurious operation Tne work order was issued to fix the oil leak.
- 5. Durin 9404661, a pump was removed and repaired,g the performance then returned to of Wgrk Order service. No vibration test was specified as the closecut for the work order. This pump (GT-503) continues to have high virati9n levels in service (per System Engineer) G-05 is a QA-Scoped piece of equipment.
Significance:
2 Inadequate documentation provided fer start failure of south bank air motors by not completing required Attachment A for troubleshooting
' purposes.
No corrective work order issued to correct degraded condition found 3.
during monthly operstion of the EDG. Alarm received during operation of the EDG and not corrected prior to returning unit to service.
- 4. Fuel oil leak not corrected by follwo-up work order. VSR2 relay required corrective rework to return to SAT condition. component to service.
HighInadequatePMTperformancepriortoreturninkhnocorrectiveaction 5
vibration observed (per System Engineer) wi to date. G-05 required to be verified as operable on a monthly frequency of testing (QA-Scope equipment).
STATUS UPDATE:
SCREENED BY : DATE: 02/17/97 REGULATORY REPORTABLE.. .. : N TS VIOLATION...... .... .. : N
. 10.CFR 21................. : N TS LCO........... . ...... : N OPERABILITY IMPACT PER TS. : N JCO REQUIRED.............. : N MSS REVIEW................ : N SCAO..................... : N OPERABILITY DETERMINATION. : N. COMITMENT . . . . . . . ........ : N SUPPORTING DETERMINATIONS:
QCR evaluation will determine if concerns are a reportability or
. operability concern.
REFERENCES:
-TS-82 WORK ORDER #9513292 TRENDING INFORMATION: "
WHEN~- : FIRS *1 QUARTER OF 1997 NON-OUIAGE
'WHO :
WHY : ' COMMUNICATION OF PNRTINENT INFO LTA.OR WAS. UNTIMELY WHAT~- : QA WORK MONITORING RELATED WORK CONTROLS RELATED SYSTEM: DIESEL GENERATOR ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE 2 .-100 DONE 03 97 3 -100 REVIEW EVALUATION 03 97 v # %
,.,3
ACTION ITEM STATUS REPORT PAGE 1 03/28/97 ,
- Responsible Person: :
- Urgency: vunE
- Trktd: OCR 97-0011
- Action-Number: 1
- Work Priority: -100
- ee*************************
Activity Pending is: DONE r
-----TITLE AND TASK DESCRIPTION------------------------------------------
Inadequate DSS notification and documentation of EDG problems i
Evaluate start-up the Quality #15, Condition commitment PMT. Report. This item was noted during the U2 4
ion ******
Sourge Record:........---DATES-02 ******* Evaluation *** ***** ****** Correct
/11/97 Comnitment: Eval Due- 03 10 97 Corr Act Due:
- Act
- .on Create: 02 26 97 Orig Evai Due: 03 10 97 Orig CA Due:
Act:.on Closed: 02 27 97 Eval Done: 02 27 97 Corr Act Done:
.......... PEOPLE-------- ------------------- --- -----------------------------
~~"
Respons4ble for Overall Action: NMS Responsible for Current Pending Activity:
Issup Manager: .
Initiator: i Punchlist Administrator:
...-------UPDATE---------------
(02 PLA Closure of Item.
' Due/27/97to input error this item may be closed to action item #3 i 1
REFERENCES-------
TS-82 ----------
WORK ORDE R # 9513292
........ -MISCELLANEOUS----
Originating Agency: --------------- S stem: DG NRC Open Item Nuder: N C Status. ,
Related Outa U2R22 )
Engineeringhes:ork Type: None,Specified <
, Person Hours: Original Estimate = I Current Estimate = l Actual Hours =
1 I
J s
l
? e i
i i
ACTION ITEM STATUS REPORT PAGE 1 03/28/97 l ******************************* Responsible Person:
i
- Trk$d: QCR 97-0011
- Urgency: DONE 2
- Work Priority: -100 l * *********
Action N. umber: ***********,*********
~
i Activity Pending is: DONE
TITLE AND TASK DESCRIPTION------------------------------------------
' Inadequate DSS notification and documentation of EDG problems Noted during start-up issue #15, PMT. Determined if DSS was/or needs to be
.made aware of thiF Condition.
l
!---- -----DATES------------------------ ------------------ ---****** ---------------
Correction ******
l Sour e Record: 02/11/97 *******
Eval Due:
Evaluat ion *********
03 10 97 Corr Act Due:
Comm tment:
l Act:.on Create: 02 27 97 Orig Eval Due: 03 10 97 02 27 97 Orig CA Due:
Corr Act Done:
Act:.on Closed: 02 27 97 Eval Done:
.......... PEOPLE--------------------------------------------------------------
Respons$ble for Overall Action: BMS __
Responsible for Current Pending Activity:
Issue Manager:
Initiator: .
Punch 11st' Administrator:
UPDATE-------- ---------------- ------------------------------------
(02/27/97 Due PLA Closure of Item.
to input error this item may be closed to item #3
REFERENCES-------------------- -------------------------------------
TS-82 WORK ORDER # 9513292 1 l
_____.----MISCELLANEOUS---------------------- ----------- -------------------- i Originating Agency: S stem: DG NRC Open Item Number: N C Status:
Related Qutages:
Engineering Work Type: None Specified Person Hours: Original Esgimate =
Current Estimate =
Actual Hours =
1 ACTION ITEM STATUS REPORT PAGE 1 l
03/28/97 j ocoeoo********ee**************** Responsible Person:
- Trkid: QCR 97-0011 Urgency: NOT DUE [~IN CLOSEOUT
!* Act 3
- Work Priority: -100 e**e, ion Number:
Activity Pending is: REVIEW EVALUATION l ----------TITLE AND TASK DESCRIPTION ---------------------- ------------------
1
! Inadequate DSS notification and documentation of EDG problems t
- Indentified during the start-up issue #15 work, PMT.
,___..-----DATES- ----- ------------------------------------------------------- l Source Record: 02 /11/97 ******* Evaluation *** ***** ****** Correction ***** i l
! Commitment: Eval Due: 03 97 Corr Act Due: !'
l' Action Create: 02/27/97 Orig Eval Due: 03 Eval Done: 03 97 97 Orig CA Due:
Corr Act L'one : !
Action Closed: J
- ----------PEOPLE-------------------------------------------------------------- ;
l i
Responsible for Overall Action: OPS Responsible for Current Pending Activity: QV Issue Manager: .
Initiaqor:
Punchlist Administrator: . _ _ . _ _ . .
.____.....-UPDATE-- -----------------------------------------------------------
(03/21/97 _. Passed to ._. for Verification.
" Conduct of Items of this which Operations" natureisare specitieu in Draft expectations B form at this time. in OMOnce1.1,hese t i
i expectations are issued, there should be complete understanding of communication standards. Evaluation Complete.
REFERENCES-------------------------------------------------------~~~
-TS-82 WOES ORDER #9513292 i
MISCELLANEOUS-- - --------------------------------------------------
Originating Agency: System: DG NRC Open Item Number: NRC Status:
'Related Outages: ,
Engineering Work Type: None,Specified l Person Hours: Original Estimate =
Current Estimate =
Actual Hours =
I
-4
CONDITION REPORT (QCR)
QCR 97-0012
~ '
STATUS: OPEN UNIT: 0- ' SYSTEM: DG INITIATED: 02/11/97 CLOSED:
ADMINISTRATOR:
MSS #: %'
INITIATOR: K ISSUE MANAGER:
NUMBER OF OPEN' ACTIONS: 1 NUMBER OF CLOSED ACTIONS: 0 ;
Specifications for.QA-Scoped equipment changed without safety evaluation -
DESCRIPTION:
- 1. Per documentation found in Work Oder 9504287, relays were found to out-of be out-of-tolerance on G-05. Relays were left tolerance and a statement added to the calibration sheetsby the, system engineer stating the as-left relays are satisfactory. No technical verification This signature providea, nor was a 50.59 safety evaluation performed.
is for a QA Scoped piece of equipment. ;
EDG monthly operability tests (TS-81 82 83 contain acceptance criteria
- 2. and the actual measured value fo,r Lube,84)l Oi Viscosity. For many of these operability procedures, the the acceptqnce acceptancelimit values fall below the has changed but no acceptable limit. In addition safety evaluation appears to ha,ve been performed for the revised, When the EDG is returned to seervice, he measured acceptance limit.
value is determined to be satisfactory.
Significance:
- 1. Incorrect _ relay calibration values for QA Scoped piece of equipment. ;
Acce tance limit for EDG lube oil viscosity not bein adhered to, a'
Revisedb>ubeOilViscosityvalueswithnoretrievablesa$etyevaluation 2.
l
(
performed.
-STATUS UPDATE: J SCREENED BY : __ .~uvud DATE: 02/17/97 )
): N : N J REGULATORY REPORTABLE..... TS VIOLATION..............( l 10 CFR 21................. J: N TS LCO.................... ( : N OPERABILITY IMPACT PER TS. J: N JCO REQUIRED.............. ( : N MSS REVIEW................ J: N SCAQ...................... ( : N OPERABILITY DETERMINATION. J: N COMMITMENT................L : N SUPPORTING DETERMINATIONS:
These -.ssues appear to not be reportability or operability concerns at this t:.me .
REFERENCES:
TS-81 TS-82 TS-83 TS-84 WORK ORDER #9504287 i TRENDING INFORMATION: ) '
WHEN--: FIRST OUARTER OF 1997 NON-OUTAGE i WHO :
WHY : LIMITS GIVEN IN PROCEDURE WERE LESS THAN AvEQUATE WHAT--: OA WORK MONITORING RELATED
-- l OPERATIONS PROCEDURE SYSTEM: DIESEL GENERATOR ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE
~^ ~ ~ ~ ~
~~~~i~~~~~ {60~~~~~dihiih~ihELUkTibh b3fl9297~
ACTION ITEM STATUS REPORT PAGE 1 03/28/97 :
- Responsible Person:
- Trk$d: OCR 97-0012
- Urgency: NOT DUE / IN CLOSEOUT Action Number: 1
- Work Priority: -100 .
Activity Pending is: REVIEW EVALUATION
TITLE AND TASK DESCRIPTION------------------------------------------
Specifications for QA-Scoped equipment changed without safety evaluation EvaluatethegualityCondition.
issue #15, PM This item was found during the U2 Start-up
- ***** ****** Correction ******
Sour e Record:-----DATES----
02/11 /97
- Evaluation Corr Act Due.:
Comm tment: Eval Due: 03 19 97 Act$on Create: 02/26/97 Oriq Eval Due: 03 10 97 Orig CA Due:
Action Closed: EvaI Done: 03 18 97 Corr Act Done:
..----- --PEOPLE--------------------------------------------------------------
Respons4ble for Overall Actigr.: EIS r Responsible for Current Pend.ng Activity: QV Issue Manager:
Initiator:
Punchlist Administrator:
......----UPDATE-------- --------------------------------- -------------------
(03/07/97 ) Passed to _ for acceptance of work.
(03/10/97 Returned to for additional work.
Changed the Due Date from; 03/10 (03/10 worx. i required to 03/19/97 l Further/97 to update calibration shee/97 ts. t (03/11/97 i Passed to ( for acceptance of work.
(03/18/97 ) Passed to for Verification.
An evaluation has been completea anu nas been submitted. The relay calibration sheet hao been marked up and forwarded to the procedure I upgrade group for incorporating in theRecommend next revisionadditional of the procedure action item for (copy attached in written response),
tracking the update of the calibration sheet in the procedure be generated and assigned to procedure upgrade group.
This item may be closed.
REFERENCES----------------------------------------------------------
TS-81 TS-82 1 TS-83 TS-84 WORK ORDER #9504287
MISCELLANEOUS---------------------- --------------------------------
Originating Agency: S stem: DG NRC Open Item Number: N C Status:
Related Outages: U2R22 Engineering Work Type: None Specified Person Hours: Original Estimate =
Current Estimate =
Actual Hours =
n s <
CONDITION REPORT (QCR)
QCR 97-0013 ;
STATUS: CGuh UNIT: 0 SYSTEM: XX INITIATED: 02/11/97 CLOSED: '
MSS #: ADMINISTRATOR:
INITIATOR: ISSUE MANAGER:
NUMBER OF OPEN ACTIrNS: 1 NUMBER OF CLOSED ACTIONS: U ITs TCPs'and PCs not'uniauely identifiable to work packages for documention of w,ork package prescribed system / component operation (Startup Issue)
DESCRI MION-During the performancq of S-P-97-01 by QA to determine that i pect-maintenance performed as prescribed testingand wasdocumented, adequately prescribed QA found that in work ITs packages,PCs ICPs and required by work orders are detached from the work orders,and There is no traceabilit' of the IT, ICP or PC
- tothespecifcworkorderoroftheworkorder[othespecificIT microfilmeda$parately. ICP or PC NeiQher the work order number nor any other unique means of ;
identification is recorded on the IT, ICP or PC to allow traceability t between these documents and the related work orders. QA noted that there is a spage on the IT form for recording the work order number; :
however, this is not used consistently. ,
Significance: Although ITs,ICPs and PCs are readily retrievable from
- e the macrofilm files maintained at PBNP they are not specifically
'identnflalble work prescribed to particular by that work work packag,The package. reviewer can only make ane to verify that they document t assumption that certain ITs ICPs or PCs were related to specific work :
orders by the dates on whicb they were performed.
STATUS UPDATE:
SCREENED BY : _ DATE: 02/17/97 N REGULATORY REPORTABLE.....( ?: N TS VIOLATION.. ...........
?N p:
10 CFR 21.................. J: N TS LCO....................
OPERABILITY IMPACT PER TS. s( p: N JCO REQUIRED.... ......... J:N MSS REVIEW........... .... J: N SCAQ......................
COMMITMENT..............
- N
- N OPERABILITY DETERMINAiION.5L s: N .
)
SUPPORTING This issue DETERMINATIONS:
is not a reportability or operability concern. t
REFERENCES:
S-P-97-01 10CFR50, APP B, CRITERION XVII TRENDING INFORMATION: 1 WHEN-- : FIRST QUARTER OF 1997 NON-OUTAGE 4 WHO :
WHY - ~: SITUATION WAS NOT COVERED BY PROCEDURE WHAT- : QA WORK MONITORING RELATED 4
PROCEDURAL PROBLEM POST MAINTENANCE TESTIfG SYSTEM: NOT SYSTEM RELATED ACTIONS PRI ACTION STATUS RESPONSIBLE PERSON DUE DATE i
~ ~ ~ ~~~ ~ ~~
~
~~~~i~~~~~.{co"~~~~ U@ihU"yER5FIbkh bh b5f55/97 i
...................................... ..................................... l l
l
}
1 l
l I
ACTION-ITEM STATUS REPORT. PAGE 1 03/28/97
- Responsible Person: .. _ . , i
- ^Trk4d: OCR 97-0013.
- Urgency: NOT vuE / IN CLOSEOUT Action Number: 1
- Work Priority: -100 Activity Pending is: ACTION VERIFICATION
TITLE AND TASK DESCRIPTION------------------------------------------ '
ITs ICPp and PCs not uniquely identifiable to work packages for docu, mention of work package prescribed system / component operation (Startup Issue)
Evaluate corrective action re of ITs ICPs andPCstoworkpackagestoafuiredtobrovidetraceabilitfyidentifiable, low recor s to be more readi and retrievable. Assign appropriate corrective actions to cognizant personnel.
02/11 /97 ******* Evaluation ********* ******
Sourge Record:----------DATES---- Correction ******
Commitment: Eval Due: Corr Act Due: 03 21 97 Orig CA Due: 03 21 97 Action-Create:
Action Closed:
02/18/97 Orig Eval Due:
EvaA Done: Corr Act Done:03 24 97
..........pcopLE--------------------------------------------------------------
Respons:.ble for Overall Action: MSV Respons:.ble for Current Pending Activity: QV Issue Manager:
Initiator: 1 Punchlist Administrator:
----UPDATE--------- - --------------------------- ------ ---------------
- (02/19/97 Changed Res From i to Changed Responsible Group:ponsible From (.Person:
M T) To (MSV)..
(03/04/97 : hanged Responsible Person: From to (03/19/97 J Passed to I for acceptance of work. ;
(03/24 Passed to for Verification.
Per dis /97cussion.s with Operations ana 1+C the following procedure groups should be included in this recommendatio,n: .
1 ORT, TS, IT, PC, RF, OIs and RPs if applicable and ICP. l Recommend adding a step to procedures to record controlling work document numbers. These steps should be added as part of the normaI revision process.
1 I
.......... REFERENCES---------------- l
MISCELLANEOUS---------------------- --------------------------------
S stem: XX
)
Originating Agency: j NRC Open Item Number: '
N C Status: 1
, Related Outages: '
Engineering Work Type: None Specified l
Person Hours: Original Estimate = l Current Estimate = 1 Actual Hours =
1 I
1 I
- ,. - . . . . - . . . . . . - . . , - - . ~ . . - . , . . . . . . . . . . . . .
i t
- - - POINT BEACH UNIT 2 COMMITMENT -
-INDEPENDENT REVIEW RESULTS -
.- Commitment ID Number 15 Commitment Description
.- g
. 1 Review 20% of the' work orders performed since January 1,1995 on Unit 2 or common PSA safety j
'significant systems (AFW, SW, EDG, IA,4.16 kv, gas turbine, and CCW) to verify adequate 1 PMT was performed to ensure system / component safety function.
Review Methodoloey -
l Determine population of work orders performed from January 1,1995 to January 1,1997 that
. affect Unit 2 or common PSA safety significant systems.
L' Verify that at least 20% have been selected and reviewed and that the selection process was not biased in a non-conservative manner.
I I
. Select a sample percentage of the those work orders previously reviewed and verify their PMT a requirements were appropriate to assure system / component safety function.
i Review Results j The PBNP staff response to this commitment is documented in the QA Surveillance # S-P-97-01. l The initial identification of affected work orders was done by determining the list of closed Work <
Orders (WO'S) for each of the seven PSA safety significant systems (AFW, SW, EDG, IA, )
4.16kv, Gas Turbine, and CCW). This population totaled 1944 WO's. A random number !
generator program was then used to select the 20% sample for review by the PNBP staff. The total number of WO's reviewed was actually 409, which slightly exceeds the 20% requirement.
An independent review of approximately 10% of the PBNP sampla was performed. The results of -
- this review are listed by WO number below. In general, no unresolved concerns ofinadequate PMT's were revealed by this review. Observations of potential issues unrelated to the PMT scope of review are provided with the affected WO review results.
I y ,, , WO,96093.8 l , no comment l , ,
WO 9611957- no comment i WO 96i2i?5t- no comment WO 96!1007- no comment-WO 9512266- no comment
.i A ..,_.
Page 1 of 3
, r , , ,
POINT BEACII UNIT 2 COMMITMENT INDEPENDENT REVIEW RESULTS Commiteant ID Number 15 WO 9602342- no comment WO 9513613- no comment WO 9513562- no comment WO 9602775- no comment WO 9601271- no comment WO 9412150- no comment WO 9501025- This work order was written to investigate the excenive loading time of the K-02B Air Compressor. A " pea size" defect on the cylinder wall was identified in the WO package with a note that it could not be removed. The impact of this defect on the operation of the air compressor with respect to excessive loading time was not addressed in the WO package.
WO 9501025- no comment WO 9612832- no comment WO 9504589 no comment l WO 9506905-This work order reset the 62/K2A (K28) time delay relay from 7 seconds to 10 seconds. There is no justification or 50.59 review for the safety significance of this change that is with the WO or with the DCN that changed DWG West.
4998466 SH. 538. Additionally, the relay as found setting was actually 12.1 seconds (not 7 seconds) and was left at 10.2 seconds. The impact of this as found/as left information was not documented for its impact on compressor operation. DCN 95-1021 for the drawing change references the wrong work order number as justification for the document change.
WO 9505338- no comment WO 9507906- no comment WO 9512305- no comment WO 9502699- no comment WO 9511573- no comment WO 9502689. no comment WO 9401387- no comment WO 9501190- no comment WO 9502305- no comment WO 9503706- no comment WO 9503707- no comment WO 9505793-no comment WO 9506768- This work order repaired tubing connections to DPIS-04007 in the Auxiliary Feedwater System. The work order specin-d a 2000 psig leak test of
~
t new'c'onnections, but a pen aEd ink dhanged this leak test pressure to 1400
' he psig. While this may be the appropriate pressure to perform this leak check, the charge is not justified or reviewed for it safety impact within the work order.
WO 9509987- no comment
- WO 9511505- no comment WO 9410619- no comment 1
(
Page 2 of 3
POINT BEACil UNIT 2 COMMITMENT INDEPENDENT REVIEW RESULTS Commitment ID Number 15 WO 9500577. no comment WO 9501147- no comment WO 9503256- no comment WO 9504612-no comment WO 9507306- no comment ,
WO 9508362- no comment )
WO '509078-no comment :
WO 9001415- no comment
)
i Recommendetions The three observations described above are provided for follow-up by the PBNP staff as appropriate. They do not affect the completion of the review of this Restart Commitment # 15. ;
. Based on this independent review, there are no items associated with this Commitment # 15 which j would impede Unit 2 Startup. !
)
a*
i l
I I
i l
, e -
i
- I .
Reviewed By: __ . . . . . _ .
U_ \
L_
Page 3 of 3
- ACTION' ITEM STATUS REPORT ~ PAGE 1~
03/31/97 ,
"******************************** Responsible Person: . . _ _ s U2R22 RESTART
- Urgency: DONE
- Trkid:/' Action Number: 16 .
- Work criority: 99 r
Activity Pending is: DONE ASSOCIATED WITH A COMMITMENT
TITLE AND TASK DESCRIPTION------------------- ----------------------
Unit 2 Refueling 22 Startup Commitments Prior to criticality complete all Unit 2 Maintenance .tule-related work order post-FMT review,s.
01/10 /97 ******* Evaluation-********* ******
Sour e Record:----.-----DATES---- Correction ******
Corr Act Due: 02 13 97 Comm tment: Eval-Due:
Action Create: 01 13 97 Orig Eval Due: Orig CA Due: 02 13 97 Action Closed: 03 31 97 Eval Done: Corr Act Done:01 20 97
PEOPLE--------------------- ----- ----------------------------------
Respons4ble for Overall Action: MPS ._
Responsible for Current Pending Activity:
-Issu Manager:
Init ator:
Punc list Administrator: ..
UPDATE-------------- -----------------------------------------------
(01/20/97 ) Passed to _. for acceptance of work.
-(01/20/97 ~~~, Passed to for Verification.
This has become part of the work control process no further action is required (03/28 This p'/97 . basPassed been tc for Final Close Out.
on-going since the fourth quarter 9f 1996. Steve Bowe indicuted that about 2% of the PMT's are being revised in this
' post-work kre-PMT review. Of that 2% nearly all the changes to PMT are being made, due to oreviously unanticipa,ted changes in the work which was '
accomplished. Thi's is ready to be closed.
(03/31/97 PLA Closure of Item.
.---------REFERENCES------------------------------------------------ ---------
...______-MISCELLANEOUS---------------------- --------- ----------------------
Originating Agency: S stem: XX
'NRC Open Item Number: N C Status:
Related Outages: U2R22 Engineering work Type: None Specified Person Hours: Original Estimate =
Current Estimate =
Actual Hours =
i a 9 g ,
f
y va; ,
POINT BEACII UNIT 2 RESTART COMMITMENT . -
INDEPENDENT REVIEW RESULTS Commitment ID Number 16 Commitment Description !
i
. Complete all Unit 2 Maintenance Rule related work order post-PMT (Post Maintenance Testing) reviews prior to the . 1
' approach to criticality. (Note that this commitment is for review of PMT's not Post-PMT's) ;
The scope of this review will be examining the idecified documents for accuracy and compliance with requirements,'
' i per the criteria in the above paragraph. Should this review identify either generic issues or significant discrepancies which could negatively impact reactor safety, the scope of the review will be expanded. Where discrepancies are . ,
. identified, appropriate corrective and preventive actions will be taken commensurate with their safety significance. !
Review Methodoloey i
' Obtain and review applicable documentation from Responsible Person. From that list select a sample to perform veri 0cationJ. Verification should consist of reviewing the WO documents to see that an appropriate PMT was conducted.
Review Results . 3 A listing ofin scope Maintenance Rule Work Orders was obtamed for the period er 10/1/96 through 2/21/97. From ,
this listing, a small sample of completed work orders was independently reviewed to verify that appropriate Post l Maintenance Testing was performed. 37 completed work orders were reviewed with no issues found with respect to !
the PMT's. It should be noted that the scope of review for this restart commitment was reduced as a result of the
. work perfonned on Restart Commitment number 15 Rastart Commitment #15 reviewed an extensive subset'of the Maintenance Rule work orders. The review for Restart Commitment #15 did not reveal any inappropriate PMT's. i NP 8.1.1, " Work Order Processing" has been revised to include a multi-disciplined group review of at least the I Maintenance Rule scoped equipment work orders for PMT's. This review is performed after the work is completed to ensure that the PMT teflects the work actually performed. This review process provides additional assurance that the proper PMT is completed for the work performed.
i The following work orders were reviewed without comment:
9604815 9608698
~
9609836 9611387 9613679 l i-9609217 9608701 9609840 '
9611743 9613989 l 9605703 9608799 9609850 9612358 9614110 9605857- 9609066 9609859 9612544 .9700428
- 9605926 9609074 9609865 9612568 9700749
.9606769 9609613' 9610497 9612946 9608288- ~ 9609808 9610523 9613368
' % 08643' 9609811 9611281 9613474 Page 1 of 2 ;
i> ;
1 POINT BEACH UNIT 2 RESTART COMMITMENT'- -
INDEPENDENT REVIEW-RESULTS -i
' Commitment ID Number 16 - I Recommendation: ;
The review of this Restart Commitment is complete without any recommendations. !
Based on this indepeadent review, there are no items associated with Commitment # 16 which would impede Unit 2 Startup.: -i i
J l
)
.. ., ; 3,:e a:- .m . . . .
ss. -
' J s j 4 <
Reviewed by:_, .
. dnl97
..<x '
y Page 2 of 2 f
u,c I ~
- - :I
ACTION ITEM STATUS REPORT PAGE 1 03/31/97
- Responsible Person: '
- Trkid: U2R22 RESTART
- Urgency: DONE
- Action Number: 33 *' Work Priority: 99 i Activity Pending is: DONE ASSOCIATED WITH A COMMITMENT !
TITLE AND TASK' DESCRIPTION--------------------------------
Unit-2 Refueling 22 Startup Commitments :
Prior to criticality implement interim improvements for the 10 CFR 50.59 process to require that all screenings be either authored or reviewed by a t member of the multi-disciplinary review team.
--DATES-------------------- ------ ----------------------------------- ,
Sour e Record: 01/10/97 ******* Eva luation ********* ****** Correction ** ***
Comm tment: Eval Due: Corr Act Due: 02 18 97 -
Action Create: 01/13/97 Orig Eval Due: Orig CA Due: 02 13 97 Action Closed: 03/31/97 Eval Done: Corr Act Done.:02 26 97 ,
PEOPLE-------------------------------------------------------------- .
~ ~ ~
Responsible for Overall Action: SPA Responsible for Current Pending Activity: ,
Issue Manager:
.InitiaQor:
Punchlist Administrator:
UPDATE--------------------------------------------------------------
(02/10/97 Requfred Training has begun for new screening in-line review mem9 b ers. reading has been issued to existing members. Last training class is on 2/12. NP 10.3.1 revision is schedule to be issued 2/14. ,
(02/10/97 .) Requested Due Date: 02/18/97 1 l
1 (02/10/97 This work is also being tracked under QCR-96-092.
(02/10/97 Changed the Due Date from: 02/13/97 to 02 NP 10.3.1 is scheduled to be issued 2/14/97. All training /18/97is expected to The requested new due date is still well before be complete by that time.
the currently expected earliest U2 criticality date.
(02/20/97 u,.ol) All training and required reading is complete. Revision to NP 10.3.1 which incorporates the interim measure of requireing all screenings to be either authored or reviewed by a member of the multidisciplinary team was issued on 2/14 of qualified multidisciplinary team members./97Training along withhasthe revised records of list classroom trainin existing members.g This givenitem to newis members complete and andmayrequired reading be closed out.given to (02/20/97 Passed to for acceptance of work.
(02/26/97 Passed to R for Verification.
New NP 10,3 1 revision issued 2/14/v4. All training complete, multidisciplinary team list has been updated. This item is complete and may be closed out.
( Passed to . for Final Close Out.
N03/28/97 o significanQ iQems (CR's) were Aum.cified during conduct of this activity. This is ready for closecut.
- a- A 9 (03 /31M7 PLA Closure of Item. ']
REFERENCES----------------------------------------------------------
NP 10.3.1
..-.-- . . MISCELLANEOUS----------------------~----------------------- --------
Originating Agency: S stem: xx
.NRC Open Ifem Nueer: NRC Status:
Related Quta,qes: U2R22 Engineering work Type: None Specified Person Hours: sOriginal Estimate = ,
Current Estimate = 1 Actual Hours =