ML20148M830
| ML20148M830 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/24/1988 |
| From: | Jablonski F, Kropp W, Plisco L, Reynolds S, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20148M812 | List: |
| References | |
| 50-440-87-25, IEIN-86-071, IEIN-86-71, NUDOCS 8804060216 | |
| Download: ML20148M830 (16) | |
See also: IR 05000440/1987025
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-440/87025
Docket No. 50-440
License No. NPF-58
Licensee:
Cleveland Electric Illuminating Company
Post Office Box 5000
Cleveland, Ohio 44101
Facility Name: Perry Nuclear Power Plants, Unit 1
Inspection At:
Perry Site, Perry, Ohio
Inspection Conducted: January 11-15, January 25-29, and February 9,1988
S. D. Eick h b
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Inspectors:
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H. A. Walker
3/2e// 7
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. Kropp, Team Leader
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Approved By:
F. J. Jablonski, Chief
c3//9/M
Maintenance and Outage Section
Da'te
Inspection Summary
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Inspection on January 11-15, January 25-29, and February 9,1988 (Report
No. 50-440/87025)
Areas Inspected:
Special, announced team inspection of licensee action
regarding an allegation and maintenance activities, using selected portions
of Inspection Procedures 62700, 62702, 62704 and 92720.
Results:
In the areas inspected, one violation was identified concerning
four specific examples of failure to follow maintenance and audit procedures
(Paragraphs 3.1.2.4, 3.1.3, 3.2.3, and 3.3.2).
With the exceptions noted,
the team concluded that overall maintenance was adequately accomplished,
effective, and self assessed.
8804060216 830331
ADOCK 05000440
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DETAILS
1.
Persons Contacted
Cleveland Electric Illuminating Company (CEI
R. Farling, President
E. Buzzelli, Licensing and Compliance Manager
M. Cohen, Maintenance Manager
W. Coleman, Operations Quality Section Manager
V. Higaki, Outage Planning Manager
W. Kandra, Operations Manager
M. Lyster, General Plant Manager
E. Riley, Nuclear Quality Assurance Department Director
C. Shuster, Nuclear Engineering Department Director
F. Stead, Perry Plant Technical Department Director
Nuclear Regulatory Comission (NRC)
H. Miller, Director, Division of Reactor Safety
The above listed individuals attended the exit meeting on February 9,
1988. Other licensee personnel were contacted as a matter of routine
during this inspection.
2.
Review of Allegations
(Closed) Allegation (RIII-87-A-136)
On October 28, 1987, the NRC forwarded several allegations to the
licensee regarding the surveillance review process, and requested the
results of the licensee's review of the concerns. The licensee had
previously received the concerns internally and had initiated an
investigation. The licensee responded to the NRC on November 25,
1987.
The inspector reviewed the licensee's response to the
allegations, observed the performance of surveillances, reviewed
procedural controls, and discussed the surveillance process with
technicians and system engineers. Based on the above, it was
concluded that the licensee's followup of this allegation was
adequate.
Concern No. 1
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Surveillance test "as found" values, which exceeded "Technical
Specifications Allowable Values," were not evaluated to determine
the impact with respect to Limiting Safety Settings.
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NRC Review
The inspector reviewed the program used to monitor instrument drift,
which was being developed but partially implemented.
Instrument
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and Control (I&C) procedures IAP-0504 and PAP-1105 required that
when an instrument's "as found" data were outside the expected
range or allowable value the associated system engineer was to be
notified for an evaluation of previous calibration data package
sheets to determine if a trend existed.
If expected I&C surveillance
test results were not achieved the Unit Supervisor was notified for
an assessment of the consequences and impact on the plant, as well as
directing the course of action to restore the instrument to service.
The inspector determined that, in accordance with 10 CFR 50.73 and
NUREG.1022, when an instrument's "as found" data were determined
unacceptable, the instrument was correctly assumed to have exceeded
the allowable value "at the time of discovery," unless other information
was available.
The inspector also determined that the Unit Supervisor's
evaluation of the condition was performed according to actions described
in the Technical Specifications, which specified that an instrument
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outside its allowable value was not indicative of exceeding a Limiting
Safety System Setting, or a Safety Limit.
For a Safety Limit to be
exceeded an actual plant event must have occurred.
Instrument failure
were reportable when the instrument failure could cause the entire safety
system to fail, or had generic impact.
Results
The concern was not substantiated. There was no impact on exceeding
Technical Specification allowable values.
It should be noted that
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the licensee recently revised procedures for initiation of Condition
Reports (CR) to require a CR for instrument "as found" deficiencies
and initiated additional personnel training. These improvements should
help ensure a more detailed review of the specific instrument drift
problems,
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Concern No. 2
Methods were inadequate to identify and trend repetitive failures of
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systems and components controlled under surveillances.
NRC Review
As noted in Section 3.1.22 of this report, weaknesses were identified
in the overall trending program and the trending program to identify
repetitive excessive instrument drift was identified as inadequate
in recent licensee audits. As a result, the licensee was developing
several programs to monitor and trend recurring instrument drift
problems and repetitive system and component failures.
Occurrences
of set point drift were not trended using the established Perry Plant
Maintenance Information System (PPMIS) because component failures were
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below the threshold of PPMIS unless an instrument could not be
re-calibrated.
Results
The concern was substantiated; however, the licensee identified
deficiencies with the trending program in previous audits and
had implemented corrective action programs.
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Concern No. 3
Instrument file folders were uncontrolled and designated as "For
Information Only/ Reference Only."
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NRC Review
The inspector reviewed several instrument file folders and determined
that the files were maintained consistent with applicable administrative
procedures.
It was noted that the file folders contained duplicate
records of documents while the official documents were maintained
according to the record management system.
The designation for
those files "For Information Only/ Reference Only" was correct.
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Results
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The concern was substantiated; however, all activities were conducted in
accordance with approved procedures.
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Conclusion
Review of the allegation did not .dentify any instances of impropriety
that would have impact on the racsological health and safety of the
public, nor were there any such instances made known to or identified
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by the inspector during the inspection.
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No violations or deviations were identified.
This matter is closed.
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3.
Evaluation of Maintenance
This inspection was conducted to evaluate activities at Perry to determine
if maintenance was accomplished, effective, and self assessed. The
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inspection was scheduled to coincide with a planned outage. The evaluation
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was accomplished by:
Assessment of backlogged corrective and preventive maintenance
Observation of maintenance activities
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System walkdowns
Review of training
Also assessed was the quality verification process related to maintenance,
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which was accomplished by:
Review of audit reports
Review of corrective action documents, such as Condition Reports,
Nonconformance Reports, and Action Requests
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Review of Trends
In preparation for this inspection, the inspectors reviewed a number
of 1987 maintenance related Licensee Event Reports (LERs). Most of
the LERs were associated with the Reactor Core Isolation Cooling (RCIC)
system. No particular maintenance related weaknesses were noted with
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the technical assessment, timeliness and effectiveness of corrective
action, or root cause analysis of the LERs.
Results of the inspection are documented in the following sections.
3.1 Pcomplishmer.:ofMaintenance
3.1.1
Maintenance Backlog
The inspectors evaluated the system for handling Work Orders
(W0s) and the safety significance of W0s not yet completed.
A large number of open W0s for various-safety-related
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systems was reviewed in detail, as well as the listing of
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all 950 open W0s.
None of the open W0s indicated a condition
that degraded safety. Most of the maintenance work was completed
in a reasonable period of time.
Priority was properly given to
work that would impact nuclear safety or_ the need to keep the
plant operating.
Deficiencies in safety systems, which did
not affect operability, were given lower priority. A review of
all open priority five (outage) work orders was also conducted
to determine if any incorrect priorities were assigned; no problems
were noted.
3.1.2
Review of Completed Work Orders (W0s)/ Repetitive Tasks
The inspectors reviewed over 50 completed W0s for completeness,
accuracy, and technical content.
Some of the specific areas evaluated
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were:
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Adequacy of work instructions;
Post-maintenance testing;
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Material control;
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Identification of root causes;
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Resolution of concerns identified during the perfomance of the
work.
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3.1.2.1
The inspectors concluded that the work instructions and post-maintenance
testing requirements were adequate.
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3.1.2.2
Concerns were identified in the areas of material control and
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identification of root causes.
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In several of the WO packages, the recorded number of parts used was
actually the number of parts removed from stores. The inspector was
informed that excess expendable and standard type material was
sometimes maintained by maintenance personnel for transfer to other
jobs as needed.
Procedure PAP-00402, "Material Request Processing,"
Revision 5, allowed the transfer of material between jobs; however,
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the procedure did not include controls for items with limited shelf
life. One item, stock code 1153379, a sealant had both safety and
nonsafety-related applications. Two batches of this sealant were
stored in the maintenance work area but one was identified as
safety-related and the other as nonsafety-related.
The sealant was
classified as nonsafety-related; therefore, it had not been evaluated
for limited shelf life. The inspector was informed that the Material
Receipt (MR) numbers were utilized to identify the material's safety
classification. The inspector reviewed "Corporate Item Master
Description Lines Data," for stock code 1153379 and determined that
two MRs were listed.
Each MR (050629 and 509103) was identified in
the maintenance storage area and on other documents as safety-related.
The inspector has concern with the evaluation of material for potential
shelf life.
This is an open item pending further NRC review
(440/87025-01).
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During review of completed work orders, the inspectors noted that a
portion had been voided or cancelled.
For example, 40% of the
Instrumentation and Control (I&C) W0s closed in the final six months
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of 1987 had been voided.
Reasons included:
"duplication," "work not
required," "problem does not exist," "no work done," and "incorporation
into another work order." A review of associated work packages and
the computerized maintenance history determined that reasons for these
voided W0s was not always documented. Also, the work control process
was designed to prevent duplication; however, there was a significant
number of duplicate W0s that required voiding. According to
Administrative Procedure, PAP-0902, "Work Request System," Revision 3,
the Project Work Center (PWC) was to review the work requests for
duplication prior to entering the approved work request in the Perry
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Plant Maintenance Information System (PPMIS) and generating a work
order. This apparently was not being effectively implemented. The
PPHIS was an established program; however, the data base utilized for
trending, the Work Order Summary sheet, was neither complete nor
adequate; therefore, the PPHIS may not be on effective tool for trending.
Recent licensee audits and self-assessments have identified weaknesses
in trending and corrective action programs have been developed.
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The above noted administrative problems did not appear to have had an
impact on the proper performance of specific maintenance tasks;
however, these types of problems could severely limit future historical
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trending and root cause analysis, and have negative impact on safe
operation of the plant due to unidentified recurring failures;
therefore, voiding of W0s is an open item (440/87025-02).
3.1.2.3
Resolution of concerns identified by maintenance personnel during
the performance of work had been previously identified by the NRC
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as an unresolved item (440/87019-02).
The licensee's action to
resolve the item had recently been incorporated into Procedure PAP 0905,
"Work Order Process", Revision 7, on December 7, 1987; therefore,
this area could not be fully evaluated by the inspectors to determine
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effectiveness of the licensee's action,
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3.1.2.4
Administrative approvals of completed work activities by operational
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and QC supervisory personnel appeared to be adequate; however, review
of completed W0s by the maintenance organization was considered weak.
The. inspectors identified numerous cases of inadequate and/or incomplete
documentation during the review of completed 'W0s.
Examples included:
WO 87-9677 - Summary description did not accurately reflect the
activity performed;
W0 87-5727, 87-10390, 88-0080 - Incomplete or incorrect corrective
action indicated on WO Closing and Summary Sheet;-
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W0 87-6175, 87-7385, 87-8746, 87-9361, 87-9498, 87-9677, 87-10213
- Incorrect or inadequate immediate failure cause identified on
the WO Closing and Sumary Sheet;
W0 87-2249, 87-8746, 87-9361, 87-9677, 87-10390 - Incorrect or
incomplete W0 closing codes;
W0 87-4825, 87-8298, 87-8597, 87-9677 - Incorrect or incomplete
Master Part List (MPL) numbers; and
WO 87-9361 - Inadequate closing summary on the WO Closing and
Sumary Sheet.
Administrative Procedure PAP-0905, "Work Order Process", outlines
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the requirements for processing work orders form initiation to closure.
The procedure required that:
a brief job or description summary was
to be filled in and updated as necessary to properly reflect the
work scope; the immediate failure cause and corrective _ action section
be completed by including the perceived cause directly identified with
the failure and a sumary of the actions taken to correct the problem;
a short, concise sumary statement of the work actually performed; and
the appropriate closing codes.
The above noted examples of failure to
follow the licensee's approved procedure in documenting completed
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maintenance activities is a violation of 10 CFR 50, Appendix B,
Criterion V (440/87025-03A).
3.1.3
Repetitive Tasks (Preventive Maintenance)
The inspectors reviewed the licensee's process to determine if
repetitive tasks were completed as scheduled or adequately justified
for deferral. The inspectors concentrated on the following task
categories: Mechanical / Electrical Preventive Maintenance (MEPM),
Protective Relay Tracking (PRT), Plant Instruments (PI), Storage
Maintenance Requirements (SMR), and Other Licensee Commitments (0LC).
The inspectors were informed that the total number of outstanding
repetitive tasks, past the late due date and not rescheduled, was
reduced from approximately 900 in mid-October 1987 to less than 100
in late January 1988.
On January 12, 1988, there were 40 outstanding
repetitive tasks in the MEPM, OLC, PRT, PI, and SMR categories.
Rather
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than actual completion of the tasks the main contributing factor in
reduction of the backlog was the rescheduling effort that took place
in late October through December 1987.
For example, 500 MEPM, PRT,
and OLC repetitive tasks were rescheduled in November and December.1987.
The inspectors _ reviewed several deferred repetitive tasks and noted
that the main reason listed for deferral was to align the repetitive
task with the new 13 week rotating schedule.
During the inspection the inspectors observed nine motor-operated
valves (MOVs) with inadequate lubrication on the rising valve stems
that can result in reduced motor operator thrust capability. Seven
of the valves were in the residual heat removal (RHR) system and
-the other two were in the liquid radwaste system. Repetitive tasks
for the 9 MOVs required inspections of the stem for adequate lubrication
every 18 months in accordance with the vendor's recommendations.
Industry valve testing has demonstrated that torque switch settings
for M0Vs have been significantly affected by inadequate lubrication
on rising valve stems. The table below lists the component number,
repetitive task number, date the task was last completed, and the late
due date, which takes into account a grace period of about five percent.
These repetitive tasks we.re rescheduled in November and December 1987.
Date Last
late
MPL
Task Number
Completed
Due Date
IE12 F0003B
R85000142
09-12-85
05-25-87
1E12 F0006B
R85000146
09-06-85
05-03-87
1E12 F0011A
R85000149
12-04-85
07-20-87
1E12 F0024A
R85000153
09-09-85
04-26-87
1E12 F0047A
R85000167
09-07-85
05-03-87
1E12 F00478
R85000168
09-09-85
05-25-87
1E12 F0064C
R85000178
11-21-85
06-20-87
1G61 F0080
R85000250
01-23-85
04-28-87
1G61 F0170
R85000254
01-23-85
04-28-87
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The reasons documented for deferring the nine repetitive tasks
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were either to be worked during second quarter of the 13 week
rotating schedule, or rescheduled to the January outage. System
engineers indicated that the M0Vs were not inspected prior to
the repetitive tasks being deferred.
Procedure PAP-0906, "Control of Maintenance Section Preventive
Maintenance," Rev.sion 1, required that rescheduled safety-
related, augmented quality, or environmental qualification (EQ)
repetitive tasks be reviewed by the responsible system engineer.
PAP-0906 further required that the signature of the responsible
system engineer indicated the engineer was aware of the task
rescheduling, agreed with the reason, and the new due date.
Procedure PAP-0906 did not require the system engineer to
perform a technical assessment to determine the effects of the overdue
repetitive tasks that occurred since September 1987, in terms of
plant safety, operability and/or reliability, nor that all other
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critical and salient aspects of the deferral were considered, and
how the evaluator reached the conclusion; therefore, this condition
is. considered a violation of-10 CFR 50, Appendix B, Criterior. V
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(440/87025-038).
(Refer to Paragraph 3.3.1 Unresolved item
440/87025-05).
Two examples of one violation and two open items were identified.
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3.2
Effectiveness of Maintenance
3.2.1.
Observation of Work Activities
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The inspectors observed portions of approximately twenty electrical
and mechanical corrective maintenance activities to determine if those
activities were performed in accordance with required administrative
and technical requirements. Activities witnessed by the inspectors
included safety and nonsafety equipment. The inspectors determined
that:
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Administrative approvals were obtained;
Equipment was properly tagged;
Replacement parts were acceptable and certified;
Approved procedures / instructions were available and properly
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implemented;
Work was accomplished by experienced and knowledgeable personnel;
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Radiological controls were established and implemented; and
Appropriate post maintenance testing was identified.
The inspectors concluded that the maintenance activities were
effectively accomplished with one exception. There was one instance
where a step in a Work Order (W0) was not signed off in proper sequence.
WO 86-15659, initiated for M0V testing, required verification of proper
stem lubrication in Step 5.4.9.
The inspector informed licensee
maintenance personnel about the missing sign-off for Step 5.4.9 and
that personnel immediately verified that the stem had proper lubrication.
The inspector subsequently verified proper lubrication of stem and
concluded that the sign-off for Step 5.4.9 was overlooked by maintenance
personnel. This missing sign-off was considered an isolated case and
did not impact hardware operability.
3.2.2
System Walkdowns
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To assess the material condition of the plant, the inspectors
performed system walkdowns of the Resident Heat Removal (RHR), High
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Pressure Core Spray (HPCS), Standby Diesel Generator (D/G), and Safety
Instrument Air (IA) systems. The inspectors also reviewed control
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room logbooks and the status of the work order backlog.
(See 3'.1)
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During the walkdowns, the inspectors evaluated housekee
equipment conditions and verified that work orders (WO) ping and
had been
initiated on noted equipment problems. During the walkdowns, the
inspectors noted very little evidence of dirt, debris, or graffito
which indicated an apparent positive management attitude towards
housekeeping; however, there were two areas of that plant where
housekeeping could be improved.
Division I and Divisdon II Standby
Diesel Generators had numerous oil leaks on the diesel engines resulting
in accumulations of oil on the floor, and a significant number of dirty
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areas. The inspectors noted that lignting was very poor ir these areas
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and may have contributed to the substandard housekeeping. The li>censee
improved the lighting and housekeeping in these areas prior to the end
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of the inspection and also initiated an Engineering Design Change
Request to add additional lighting fixtures in the D/G rooms.
Specific material condition deficiencies were noted and with
one exception, identified for correction on open W0. This
one exception pertained to the HPCS water leg pump. During
a preliminary plant walkdown on Decembar 15, 1987, the inspectors
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noted a significant accumulation of oil on the baseplate of the HPCS
water leg pump (1E220002).
As a result, oil had also dripped on the
floor below the pump. During a subsequent walkdown, on January 12,
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1988, the inspectors again noted the accumulation of oil. The inspector
determined that a W0 had not been initiated to correct.the apparent
leak. The licensee stated that the oil in the pump was renewed on
October 8, 1987, and in the process oil probably had been spilled and
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not cleaned up. The licensee cleaned up the oil and monitored the pump
for leakage. On January 28, 1988, the inspector observed another
accumulation of oil. Upon further questioning, the licensee responded
on January 29, 1988, by initiating a work request to investigate the
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oil leak. Operability of the pump was not affected since an oil level
indicator was periodically checked by the plant operator on routine
rounds; however, this condition existed for more than one month and
required NRC prompting to have a work request initiated to investigate
the potential leak. During a walkdown of the plant prior to the exit
meeting on February 9,1988, the inspector noted that the leak had not
yet been corrected and the oil level was low. At the exit meeting,
the inspector infonred the licensee that this condition was unacceptable.
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During system walkdowns, the inspectors noted that the majority of
components such as valves, gauges, and panels were labeled and
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identified with at least a MPL number; however, several important
controls and indicators were not labeled. For example, the
Division II D/G local voltage regulator switch did not have a nameplate,
labels for the indicator lights, nor a pointer on the handswitch. The
licensee had initiated actions to improve plant labeling as a result
of previous internal findings.
These actions, when implemented, should
assist the operators in proper identification of all components.
The
licensee stated the labeling program was scheduled to be completed by
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June 1988.
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As discussed below in Paragraph 3.2.3, the inspectors noted pocr
conditions on many valve stems throughout the plant including
excessive dirt and/or inadequate lubrication.
Several valve stems
appeared to have no lubrication and paint was also observed on the
stem threads.
3.2.3
Valve Maintenance
During walkdowns of the RHR and other selected systems, the following
concerns were identified with M0V stem lubrication and procedures
PMI-0030, "Maintenance of Limitorque Valve Operators", Revision 1,
and GEI-0056, "MOVATS Testing", Revision 1:
RHR valves 1E12-F0087A and B, had "Neolube" brand lubrication
on the valve stems instead of "Nebula EP0" required by PMI-0030.
There was no objective evidence to substantiate that valves
1E12-F0087A and B had been cycled electrically and manually
as specified in the post maintenance requirements of PMI-0030;
licensee personnel confirmed tnat the valves had not been
cycled.
Valve 1E12-F00248 had two types of lubrication applied to the
stem; "Neolube", as required by procedure GEI-0056, and "Nebula
EP0" as required by procedure PMI-0030.
The licensee did not
perform an engineering analysis to determine compatibility of the
lubricants.
Based on the inspector's observation, the licensee
took immediate corrective action by issuing FCR 8945 to address
the compatibility of "Neolube" and "Nebula EP0."
Also, the
licensee revised PMI-0030 and gel-0056 to standardize the stem
lubrication of MOVs to "Never-Seez."
WO 87-10643 included a QA inspection report that documented the
use of "Nebula EP0" as a stem lubricant, and a stores requisition
for that lubricant.
Discussions with maintenance personnel,
engineers and the QA inspector, along with observation by the
inspector indicated that instead of "Nebula EP0," "Neolube" was
used as the stem lubricant.
Upper bearing grease Zerk fittings on valves 1E12-F006B and
1E12 F003B appeared clean or painted over which suggested to
the inspector that the upper bearings had not been lubricated
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as specified by the manufacturer of the MOV operator. The
licensee revised PMI-0030 to include steps to lubricate the
upper bearing through the Zerk fitting.
As a result of the inspector's observations and concerns, the
licensee promptly initiated a review and had begun corrective
measures as stated.
Failure to properly control valve lubrication
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appeared to be the result of inadequate instructions / procedures for
maintaining proper lubrication. This is a violation of 10 CFR 50,
Appendix B, Criterion V, which requires that activities affecting
quality be prescribed by instructions, procedures, or drawings of a
type appropriate to the circumstance (440/87025-03C).
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3.2.4
Control Room Logbook Review
The inspectors reviewed control room logbooks for the months of
November and December 1987 to determine if identified operational
problems were promptly .followed up with a written W0. The inspectors
selected 15 operational anomalies during .the period and determined
that all occurrences were followed up with a W0, or were corrected
during the performance of a surveillance test.
In cddition, the
inspector noted that recurring hydraulic control units (HCU)
accumulator alarms had occurred on the same HCOs and W0s were initiated
on the appropriate units.
3.2.5.
Training
Training and qualification records were reviewed for 14 maintenance
personnel that participated in maintenance activities witnessed by
the inspectors. Training files were available for 9 of the 14; 4 of
the 9 files reviewed did not have resumes or other objective evidence
that the individuals had the required education and experience to
perform the respective work; 3 of the 4 resumes were not current and
did not indicate the required experience levels; and current Perry
plant related experience was not listed on the resumes reviewed.
During discussions with licensee personnel the inspector was informed
of the following:
training records were intended to provide a record of
training for Perry plant personnel;
resumes and other objective evidence of qualifying experience
for Perry plant personnel were maintained by the maintenance
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organization; and
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training and qualification records for contractor personnel were
the responsibility of the respective contractor.
Individual training and qualification records were located at various
locations and appeared to be difficult for the licensee to control and
use. Time was not available for the inspector to review the records
at the various location and determine if inadequate training contributed
to the related problem observed by the inspectors. This item is open
and will be reviewed on a subsequent inspection (440/87025-04).
The inspector noted that training and qualification problems were
identified by the licensee during the INP0 Maintenance Self Assessment
which was completed in November of 1987.
3.2.6
Summary of Maintenance Accomplishment and Effectiveness _
Maintenance activities observed during the inspection were accomplished
in an effective manner. Although the training and qualifications
records for maintenance personnel appeared to be difficult for the
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licensee to control, the maintenance personnel observed appeared to be
knowledgeable and professional. Licensee procedures described the
maintenance work process in sufficient detail; however, conflicting
maintenance procedures existed in the area of valve stem lubrication.
The inspectors concluded that the housekeeping and material condition
of the plant was adequate; however, based on the material condition
problems identified with nine MOVs, the HPCS waterleg pump, and the
oil leaks on the D/G, it appeared that there was a need for greater
attention to detail by the plant staff including active plant management
involvement by participating in routine plant walkdowns. An ambitious
preventive maintenance program has been established; however, the
inspectors were concerned about the inadequate or lack of technical
assessments for deferrals in the later part of 1987.
An example of one violation and one open item were identified.
3.3
Quality Verification
The inspectors reviewed corrective action documents and audit reports
to evaluate the licensee's quality verification process. These
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documents were reviewed for root cause analysis, timely corrective
action, trend analysis, technical assessments, and justifications
for close out of corrective action documents.
3.3.1
Action Requests, Condition Reports and Nonconformance Reports
The nonconformance reports and condition reports reviewed were
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determined to have proper corrective action and justificat; < for
close out. Action requests (AR) were corrective action documents
issued by the licensee's QA Department to document deficiencies
identified during audits, surveillances, or at any time when deemed
necessary.
Based on these reviews, it appeared that the effectiveness
of the corrective actions associated with ARs was not evaluated prior
to closing the ARs. Discussions with licensee QA personnel determined
that the effectiveness of corrective action was evaluated utilizing
three methods.
One of the methods used the AR itself as the document
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to record the evaluation. The other two methods utilized either a
surveillance or an audit. Since these two methods were not defined
in the licensee's QA Program, this area needs further review in a
subsequent inspection.
The inspectors did have a concern with AR 0155
issued in September 1987. This AR identified an increasing trend in
outstanding repetitive tasks that affected various equipment.
Specifically,150 Limitorque valve operator maintenance tasks were not
performed which was a violation of the licensee's internal response to
This response referenced PMI-0030 for
the performance of those maintenance tasks.
The AR was closed by the
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licensee's QA department based on corrective action that addressed the
rescheduling of approximately two-thirds of repetitive tasks thus
reversing the increasing trend of outstanding repetitive tasks.
Various
reasons were identified in the corrective action for rescheduling the
repetitive tasks. The reason for rescheduling the 150 Limitorque
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valve operators was that these repetitive tasks required either a plant
or a system outage. There was no objective evidence that the
rescheduling was evaluated for impact and significance to plant safety
and reliability. Pending further reviews of this matter, evaluation
of the effectiveness of corrective action associated with the closure
of ARs is an unresolved item (440/87025-05).
(Refer to Paragraph 3.1.3,
Violation 440-87025-03B).
3.3.2
Audits
The inspectors reviewed audit reports conducted in 1986 and 1987.
The audit reports pertained to corrective action, equipment
lubrication, equipment status, repetitive tasks (preventive
maintenance), special process and warehouse activities.
The
audits conducted in 1987 evaluated processes and programs for
technical adequacy, as well as verification of compliance to
procedures.
It appeared that the licensee had enhanced the
audit program since 1986 to accomplish technical assessments that
should be useful to management in the identification of safety
significant issues.
The 1987 audit of equipment lubrication was
an example of an audit that not only verified procedural or
programmatic compliance but also a technical assessment of the
method for sampling oil.
Another example of a "performance related" audit was Audit 87-12
"Ef fectiveness of Corrective Action." This audit report identified
several deficiencies that were identified during a previous audit
and documented on Action Requests (AR); however, some deficiencies
not previously documented on ARs were identified during Audit 87-12
as observations. Observations, by definition, are not part of the
established licensee corrective action system so observations are not
subject to close scrutiny and attention by management. One observation
was that condition report investigations were not completed in a timely
The observation further stated that corrective actions were
manner.
not effective in dealing with previous NRC concerns about untimely
corrective action.
10 CFR 50, Appendix B, Criterion XVI requires that
significant deficiencies be promptly identified and corrected; therefore,
the observation in Audit Report 87-12 pertaining to untimely corrective
action was a deficiency that should have been required to be documented
as an AR to assure prompt corrective action, Procedure NQAD 1840, "Audit
Performance," required deficiencies identified during an audit be
documented on a AR.
Failure to document deficiencies identified during
Audit 87-12 is a violation of 10 CFR 50, Appendix B, Criterion V.
(440/87025-030).
3.3.3
Corrective Action Programs
The inspectors reviewed numerous problems with the diesel generator
control air system to evaluate the effectiveness of the licensee's
corrective action for equipment problems.
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On March 11, 1987, the Division I D/G control air system failed
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during an overspeed trip test. As a result of troubleshooting
a new regulator and air filter were installed and aluminum filings
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were found in the failed regulator.
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The licensee initiated Condition Report (CR)87-124 on March 11,
1987, describing the initial regulator failure on the Division I
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D/G. The investigation summary stated that the failure was
attributed to the age of the installed regulator with a possible
contributing factor being the tr,etal filings. This failure, and
subsequent failures of the replacement regulators prompted the
licensee to initiate design change DCP 87-0233 on April 1, 1987.
This DCP upgraded the pressure regulators. Upgraded regulators
were installed in both divisions by April 10, 1W /.
It should be
noted that the Special Report to the NRC on March 27, 1987, did
not provide any cause for the failure except that the regulator
failed to provide the required output of 60 psig.
The CR was
closed on June 22, 1987, but not deemed significant enough to be
reviewed by the Plant Operations Review Committee (PORC).
(Technical Specification 6.5.1.6, Items g. and h.)
On October 15, 1987, the Division II D/G failed to flash its field
during a scheduled routine surveillance test. Troubleshooting
disclosed oil on the diaphragm and small metal filings in the
shuttle valve.
The work order Closing and Summary Sheet did not
state that metal filings were found in the shuttle valve.
CR 87-481, issued on October 15, 1987, documented this event, but
also did not state that metal filings had been found. The root
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cause was stated to be an indeterminate malfunction in the pneumatic
control circuit with the shuttle valve as the suspect component.
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Corrective action included a design change to replace the shuttle
valve with electro-mechanical relays.
The modification was
installed on the Division 11 D/G; however, the CR had not been
closed since the modification was not installed on the Division I
D/G. Like CR 87-124, CR 87-481 was not deemed significant enough
to be reviewed by the PORC.
(Technical Specification 6.5.1.6,
Items 9. and h.).
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The Special Report to the NRC on November 13, 1987, which described
this valid test failure, stated that the shuttle valve apparently
failed to reposition on the start signal. The special report also
stated that a design change was initiated to eplace the shuttle
valve with electro-mechanical relays. The Special Report did not
mention the metal filings found in the shuttle valve.
Although the licensee initiated action to correct the control
air system problems, the inspectors were concerned that on
two occasions the Special Reports submitted to the NRC did
not state that metal filings were found by the licensee,
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Regulatory Guide 1.108 stipulates that the cause of the
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failure be included in the failure report. The inspectors
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were also concerned that four CRs pertaining'to failures of
the diesel generator control air system were not considered
significant enough for review by the PORC even though the
CRs were issued over an eight month period. The licensee
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noted in recent internal audits that the corrective action
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system needed to be strengthened and action was being taken
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to improve the system.
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3.3.4
Sumary of Quality Verification
The inspectors concluded that improvement was.needed in the area of
closing ARs.
In some cases, there was insufficient evidence to support
the closure of ARs and there was lack of objective evidence that
effectiveness of corrective action was evaluated.
It appeared that
the licensee's QA department was making progress towards audits and
surveillances which not only evaluated procedural. compliance but also
evaluated processes and programs for technical adequacy.
An example of one violation and one unresolved item were identified.
3.4
Conclusions
Based on inspection activities described in this report, the
inspection team concluded that maintenance was accomplished,
effective, and self assessed as noted below:
The threshold for placing equipment problems on maintenance
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work requests was sufficient to maintain the material
condition of the plant at an acceptable level; however,
increased attention to detail by operators / management during
plant tours is warranted.
High and low priority maintenance tasks were adequately tracked
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by the PPMIS system; however, documentation throughout the
work order process was not effectively implemented, which may
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deter the capability to develop and maintain meaningful equipment
history.
Licensee management attention and involvement in maintenance
was evident and resources were adequate and reasonably effective.
The inspection team was concerned with what appeared to be a lack
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of technical assessments when rescheduling repetitive tasks.
Training and qualification records for maintenance personnel
appeared to be difficult for the licensee to control and use;
however, no problems were noted with the actual maintenance
activities observed.
Relationship of training to other
weaknesses observed by the inspectors during system walkdown
needs to be assessed by the licensee.
The QA Department made progress towards audits and surveillances
that evaluated processes and activities for technical adequacy;
however, improvements are needed in closure of Action Requests
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after verifying effectiveness of corrective actions, and the
identification of deficiencies during audits.
4.
Open Items
Open itens are matters that have been discussed with the licensee,
which will be reviewed further, and involve some action on the part
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of the NRC or licensee or both. Open items identified during the
inspection are discussed in Paragraphs 3.1.2.2 and 3.2.5.
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Unresolved Items
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, violations,
or deviations. An unresolved item disclosed during this inspection
is included in Paragraph 3.3.1.
6.
Exit Interview
The inspectors met with licensee representatives (denoted in Paragraph 1)
on February 9,1988, at the Perry Nuclear Power Plant and summarized the
purpose (scope) and findings of the inspection.
The inspectors discussed
the likely content of the inspection report with regard to documents or
processes reviewed by the inspectors during the inspection. The licensee
did not identify any such documents or processes as proprietary,
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