ML20148M830

Insp Rept 50-440/87-25 on 880111-15,25-29 & 0209.Violations Noted.Major Areas Inspected:Licensee Action Re Allegation & Maint Activities

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: ML20148M830
References
50-440-87-25, IEIN-86-071, IEIN-86-71, NUDOCS 8804060216
Download: ML20148M830 (16)

See also: IR 05000440/1987025

Text

._ .. _ . - . . . ._

',~ '.: ,

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

Inspectors: S. D. Eick h b 1/e4/#a

Date

t% W shdtf

Date

'

3lE'f

Date

h

H. A. Walker

k 3/2e// 7

Date

. . Kropp, Team Leader 2

Date

0

Approved By: F. J. Jablonski, Chief

Maintenance and Outage Section

c3//9/M

Da'te

Inspection Summary

i 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

PDR ADOCK 05000440

0 DCD

., ..

.

..

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 ,

1

Surveillance test "as found" values, which exceeded "Technical i

Specifications Allowable Values," were not evaluated to determine  !

the impact with respect to Limiting Safety Settings. j

!

l

NRC Review

The inspector reviewed the program used to monitor instrument drift, l

which was being developed but partially implemented. Instrument l

l

l

l

2 l

_m - . ._. .___ _ _ _ __. . . .

, ..

,

.. .

.

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 '

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 ,

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,

i

Concern No. 2

Methods were inadequate to identify and trend repetitive failures of

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 ,

below the threshold of PPMIS unless an instrument could not be l

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. )

l

3 )

l

,

,.-,-e -

,.e --ma--,. -m.-, ~ . - - - - - - , c--, - --m,y, ,. .-- -

er - , - -

1= -

. . . . - _ . _ _ _ . . _. _ _ _ _ _ _ - .

'. *:

..

A

Concern No. 3

Instrument file folders were uncontrolled and designated as "For

Information Only/ Reference Only."

.

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.

,

Results .

1

The concern was substantiated; however, all activities were conducted in

accordance with approved procedures.

.

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 l

by the inspector during the inspection.  ;

!

No violations or deviations were identified. This matter is closed. i

3. Evaluation of Maintenance

This inspection was conducted to evaluate activities at Perry to determine  ;

if maintenance was accomplished, effective, and self assessed. The '

inspection was scheduled to coincide with a planned outage. The evaluation i

. was accomplished by:

Assessment of backlogged corrective and preventive maintenance  ;

Observation of maintenance activities  !

System walkdowns

Review of training  ;

1

Also assessed was the quality verification process related to maintenance, I

which was accomplished by:

Review of audit reports

Review of corrective action documents, such as Condition Reports, l

Nonconformance Reports, and Action Requests '

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

i

-

4

. _ - - _ ._.

-

_ . . _ , - . _ - _ _ _ _ _ _ _ _ _ _ _ _ ,

- . ~ . . . --. . - . _ . - . _ .

- r.

, .

.

i

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 i

systems was reviewed in detail, as well as the listing of i

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 '

were: ,

Adequacy of work instructions;  ;

'

Post-maintenance testing;

Material control; i

Identification of root causes;

Resolution of concerns identified during the perfomance of the l

work. j

3.1.2.1 The inspectors concluded that the work instructions and post-maintenance

, testing requirements were adequate.

'

i 3.1.2.2 Concerns were identified in the areas of material control and

f

1

identification of root causes.

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,

.

5

._ _ . _ - _ . . _ _ _ _ _ . - , . _ _ _ _ _ _

_ _ _ _ _ - _ _ _ _ -_

- - . .- . . -- .

b. *:

.

.

.

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).

'

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

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

l

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. ,

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 ,

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 '

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 '

effectiveness of the licensee's action,

.

6

i

_ _ _ _ _ _ _ _ - . - - - - - - - - - - - - ___J

- . . . -- .

,

.

~: .

.

. 3.1.2.4 Administrative approvals of completed work activities by operational

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;-

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 '

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

1 follow the licensee's approved procedure in documenting completed

i

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

7

-- -

, ., ._ . _

.. --

. -

> ','.

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

i

The reasons documented for deferring the nine repetitive tasks q

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

I

!

8

.- . . _ _ _ _ . _ - _ _ _ _

',.

e ,

,

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 >

(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. i

3.2 Effectiveness of Maintenance

3.2.1. Observation of Work Activities

.

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: ,

Administrative approvals were obtained;

Equipment was properly tagged;

Replacement parts were acceptable and certified;

'

Approved procedures / instructions were available and properly

implemented;

Work was accomplished by experienced and knowledgeable personnel;

i

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 )

l

To assess the material condition of the plant, the inspectors l

performed system walkdowns of the Resident Heat Removal (RHR), High 4

Pressure Core Spray (HPCS), Standby Diesel Generator (D/G), and Safety l

Instrument Air (IA) systems. The inspectors also reviewed control l

room logbooks and the status of the work order backlog. (See 3'.1)

9

.________ _ _ _ _ _ _ _ _ A

__ _

_ _ . __ __ _

. .

[. .

i

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 '

areas. The inspectors noted that lignting was very poor ir these areas '

and may have contributed to the substandard housekeeping. The li>censee

improved the lighting and housekeeping in these areas prior to the end .

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 t

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,  !

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 '

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

l 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.

1

During system walkdowns, the inspectors noted that the majority of

. components such as valves, gauges, and panels were labeled and

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

i June 1988.

1

,

10

1

__ __ _ _ - _ . . _ - _ _ _ . _

__ _ _ _ _ ,

N .'.

.

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 ,

as specified by the manufacturer of the MOV operator. The l

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

appeared to be the result of inadequate instructions / procedures for l

maintaining proper lubrication. This is a violation of 10 CFR 50,

Appendix B, Criterion V, which requires that activities affecting l

quality be prescribed by instructions, procedures, or drawings of a l

type appropriate to the circumstance (440/87025-03C). l

1

11 l

1

• *

. ,

.. -

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 ,

organization; and  !

l

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

12

- . ~ . .- .__

)

,..

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 '

!

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 ,

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 i

three methods. One of the methods used the AR itself as the document >

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 l

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

NRC Information Notice 86-71. This response referenced PMI-0030 for

- the performance of those maintenance tasks. The AR was closed by the

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

13

!

i'

- - . . _-. - - -- . - . . .a

.

.' -

'

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

manner.

The observation further stated that corrective actions were

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

I

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. i

On March 11, 1987, the Division I D/G control air system failed i

I

during an overspeed trip test. As a result of troubleshooting

a new regulator and air filter were installed and aluminum filings 3

'

, were found in the failed regulator.

14

i

.. _ . - . _ _ __. _ . _ _

'*

.. .

-

.

,

'

,

The licensee initiated Condition Report (CR)87-124 on March 11,

1987, describing the initial regulator failure on the Division I ,

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

cause was stated to be an indeterminate malfunction in the pneumatic '

control circuit with the shuttle valve as the suspect component. 4

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.).

,

l 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, j

Regulatory Guide 1.108 stipulates that the cause of the )

'

failure be included in the failure report. The inspectors

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 ,

5

noted in recent internal audits that the corrective action 1

system needed to be strengthened and action was being taken

'

l

to improve the system. l

l

!

15 )

. . . . _ . - - - - . - _ . ..

. . . . . . -- ._ . . .

.- .'.

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

-

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 j

by the PPMIS system; however, documentation throughout the

work order process was not effectively implemented, which may .

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. l

The inspection team was concerned with what appeared to be a lack j

of technical assessments when rescheduling repetitive tasks. l

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 l

after verifying effectiveness of corrective actions, and the i

identification of deficiencies during audits.

l

4. Open Items I

Open itens are matters that have been discussed with the licensee,  ;

which will be reviewed further, and involve some action on the part i

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.

16

_- --

'.,

.

..

.

5. 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,

l

l

!

!

!

l

17 l

l