ML20149M514

Insp Rept 70-1151/96-05 on 961029-1101.Violations Noted. Major Areas Inspected:Facility Support - Maint

ML20149M514
Person / Time
Site:	Westinghouse
Issue date:	11/27/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149M507	List: ML20149M506 ML20149M512 ML20149M514
References
70-1151-96-05, 70-1151-96-5, NUDOCS 9612170251
Download: ML20149M514 (14)

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S U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-1151 License No.: SNM 1107 Report No.: 70 1151/96 05 Licensee: Westinghouse Electric Corporation Facility: Commercial Nuclear Fuel Division Columbia, SC 29250 Inspection Conducted: October 29 - November 1, 1996 Inspectors: C. Bassett, Senior Radiation Specialist l

Approved by: E. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety l

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l Enclosure 2 9612170251 961127 PDR ADOCK 07001151 C PDR

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l EXECUTIVE

SUMMARY

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Commercial Nuclear Fuel Division 1 70 1151/96 05 l FACILITY SUPPORT - MAINTENANCE o The maintenance function is organized and staffed adequately to perform the maintenance function at the facility. The Maintenance, Planning,  !

and Control GiAPCON) computer system is a powerful and useful tool, the full capability of which is still being developed by the licensee.

o In general, the maintenance procedures are adequate to provide I reasonable assurance that maintenance activities at the site will be l performed in a safe manner. One exception is that safety related preventive maintenance (PM) is apparently allowed to be overdue for two weeks before any administrative action is begun.

• Work orders (W0s), which control all work performed by the maintenance organization, are being completed properly and contain special instructions and controls as needed, e Maintenance activities at the facility are being performed by qualified individuals. 1 e No formal management audit is conducted in the area of maintentnce.

l e Reporting of maintenance problems can occur through the use of the " Red i Book" but generally occurs by other means. The licensee uses various approaches in response to problem identification from assigning an engineer to develop corrective action to forming an investigation team to look into the problem.  !

e Surveillance testing is being conducted within the specified frequencies as required by procedure, the procedures contain adequate guidance, and the test results are in conformance to written requirements.

e Instrument calibration is being conducted within the frequencies l outlined by procedure, the 3rocedures used contain adequate guidance, j and the results of the cali) rations conform to specified requirements.  ;

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e Preventive maintenance is generally being conducted within the specified I frequencies as required by the License Application. One exception was I noted of the 3-month PM that was scheduled for the #1 North American l Boiler between the period of June and September 1995. The PM was not conducted within the 115 day period allowed by the License Application which is an apparent violation.  ;

Attachment:

l Partial List of Persons Contacted l Inspection Procedures Used l List of Items Opened, Closed, and Discussed j List of Acronyms l

Report Details IV. Facility Support F1 Maintenance / Surveillance (88025)

F1.01 Conduct of Maintenance

a. Inspection Scoce The licensee's maintenance organization was reviewed to assess the effectiveness of the program,

b. Observations and Findinas The maintenance organization is composed of a maintenance manager, five maintenance team managers, two maintenance engineers, a maintenance coordinator, a secretary, 52 mechanics, 23 technicians, and 18 electricians. Of the mechanics, technicians, and electricians, six function as planners and two as training coordinators.

The maintenance manager reports to the manager of manufacturing who reports to the Plant Manager. The team managers report to the maintenance manager and each is assigned a specific area of responsibility including electrical systems; heating, ventilation, and air conditioning; instrumentation; predictive maintenance; and, as an aggregate, the various systems and equipment in the chemical area of the plant. Four of the team managers are assigned to day shift and the fifth team manager works on second and/or third shift. The maintenance engineers deal with problems associated with the areas outlined above, with one engineer being assigned the specific responsibility to maintain and oversee the functioning of the licensee's computer system and database designated as the MAPCON computer system. MAPCON is an integrated relational database computer system useu to collect and report on maintenance costs, to assist in scheduling work, to order and track parts, and track time spent on each maintenance job. The planners schedule work, write work orders, get the needed materials and equipment for the various jobs in progress or that are scheduled to be wrformed during the shift, and track the progress of the work that is wing performed. The training coordinators conduct training classes in job-related subjects, provide training materials and films for the other maintenance workers, and u Minate special training classes with a local technical college. The mechanics, technicians, and electricians perform the work and complete the tests and calibrations that keep the various systems, instruments, and equipment in an operable condition.

In addition to the above and as a result of previous problems in following work orders dealing with safety-related equipment, one individual has been assigned to track such work orders. Another individual, the maintenance secretary, has been assigned the task of closing out all the work orders and is the only person with that assignment.

w 2 i The licensee employs contract workers in the maintenance area but has recently eliminated all but two contract organizations. One contractor supplies custodial and grounds personnel, as well as approximately 36 electricians: the other contractor operates the licensee's storeroom.

The licensee had operated the a Maintenance, Repair, and Operations l (MRO) storeroom as part of the maintenance organization but recently turned over that operation to a separate contractor. The contractor maintains the licensee's inventory through the use of the licensee's MAPCON computer system.

I c. Conclusions 1

The maintenance function is organized and staffed adequately to perform the maintenance function at the facility. The MAPCON computer system is a powerful and useful tool, the full capability of which is still being developed by the licensee. ,

F1.02 Work Control Procedures

a. Inspection Scope Maintenance )rocedures were reviewed to determine that they required a i "special wor ( permit" for maintenance activities; required review and approval of the work permit: required the concurrence of the operations group for the work to be performed, a release of the equipment for maintenance, and approval and/or acceptance of the work performed; and defined the criteria under which the work was to be completed.

b. Observations and Findinas The inspector reviewed selected maintenance procedures including the following:

e Maintenance and Calibration Procedure (MCP) 108000, Preventive Maintenance, Revision (Rev.) 2, dated October 21, 1993 e MCP 108103, Work Order Handling, Rev. 3, dated January 11, 1996 e MCP 108105, Equipment Set Up, Rev. 1, dated November 30, 1995 ,

1 The maintenance procedures reviewed required a "special work permit" for  !

maintenance activities. This was stipulated as a " work order" and a W0 l was required to be generated for each maintenance job. The W0 was required to be reviewed and approved prior to initiation of the work:

the W0 also required the concurrence of the operations group for the work to be performed. The W0 defined the criteria under which the work was to be completed by means of a safety checklist. The safety checklist stiaulated special controls (if needed) such as a radiation work permit (RWP), bioassay, special air sampling, protective clothing I

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5-3 and/or equipment, a cutting and welding permit, a fire watch, tank entry permit, and a functional test following work on safety related equipment-(SRE). The W0 also contained a release of the equipment for maintenance and approval and/or acceptance by the operations group of the work performed by maintenance personnel.

During the review of the procedures, the inspector noted that delays could occur in the completion of W0s. Procedure MCP 108000 indicates in Section 4 that the " owner" of the equipment or instrumentation (recuiring preventive maintenance) must review the safety significance of celays or cancellation of scheduled PM and must authorize the first delay (a week after the PM was due). The Area Manager must review the safety significance of delays or cancellation of scheduled PM and must authorize the second delay (two weeks after the PM was due). The staff-level manager must review the safety significance of delays or cancellation of scheduled PM and must authorize the third delay (three weeks after the PM was due). The inspector discussed this process with the individual who had been assigned responsibility for tracking the completion of safety related PMs. The individual indicated that he receives a printout of the overdue safety related PMs every week. There is a one week " grace" period built into the system. After two weeks the overdue PM is placed on a tracking board located in one of the team managers' offices and the Area Manager is issued a letter documenting the overdue PM and requesting a resmnse on what will be done to correct the situation. If, after three wee (s, the PH has not been completed, a

-letter is sent to the staff manager requesting a response. According to the licensee, prior to having an individual assigned to the task of tracking overdue PMs, there was a lack of emphasis placed on completing the safety related PMs on time. Since one person has been assigned to track the overdue PMs, the incidence of non compliance has dropped and the licensee no longer considers this a problem. The inspector noted that apparently nothing happens concerning an overdue safety related PM until two weeks after it was due.

c. Conclusions Based on this review, the inspector determined that, in general, the procedures were adequate to provide reasonable assurance that maintenance activities at the site would be performed in a safe manner, One exception is that safety related preventive maintenance is apparently allowed to be overdue for two weeks before any administrative action is begun, F1.03 Work Control Authorizations

a. Insoection Scope i

W0s were reviewed to determine that they were being completed properly, that they required specific authorization for maintenance activities involving welding, open flame, or other ignition sources, and that they

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required a special survey or evaluation of any proposed work to be performed in the vicinity of flammable material, vital cable runs, and ,

critical process equipment. l

b. Observations and Findinas ,

The inspector reviewed numerous W0s for the period during the past six months and selected W0s from the past two years. It was noted that the licensee maintains a "hard copy" of W0s for the previous three to six months. Beyond that time, the W0s are archived and maintained in the computer system. The inspector verified that the W0s contained the proper authorizations when s)ecial activities were to be completed such as weldir.g. The safety checclists had also been completed as required and contained requirements for special surveys, protective clothing, air sampling, res)irators, auxiliary ventilation, and special permits as required by t1e situation.

The inspector also observed work in the chemical area of the plant and reviewed the W0s associated with those jobs. The specific work observed and W0s reviewed included:

e WO Number (#) 137375, Conversion Line 2 UF . Nitrogen, Eduction -

Transport Pi)ing, issued September 27,1998. The work involved i performing t1e annual preventive maintenance on the UFs nitrogen j line check valve.

e WO# 139981, Conversion Line 5 Westfalia Decanter, issued October 30, 1996. The work involved disassembling the decanter for cleaning and changing out the feed end bearing.

e WO#140003, Conversion Line 2 Westfalia Decanter, issued October 30, 1996. The work involved removing the decanter from Conversion Line 5 and installing that decanter on Line 2.

e WO# 140006, Conversion Line 2 Hot Oil Dryer, issued October 30, 1996. The work involved repairing leaks on the flow switch at the piping elbow.

The inspector noted that the W0s had been properly completed, the maintenance work had been authorized, and special controls were stipulated as needed. It was also noted that the W0 dealing with preventive maintenance contained additional guidance detailing the disassembly, inspection, and reassembly of the valve and included a listing of the materials that would be needed for the job, the cost of the materials, and the estimated time required to complete the work.

Interviews with those maintenance personnel involved with the job indicated that they were aware of the scope of the work to be performed, were aware of the special controls in place to stipulate added safety I precautions for the job, and were knowledgeable of what was required to i

complete the work.

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c. Conclusions j W0s, which control all work performed by the maintenance organization, were being completed properly and contained special instructions and controls as needed.

F1.04 Qualifications of Maintenance Personnel

a. Inspection Scope Maintenance personnel qualifications were reviewed to ensure that maintenance activities were being performed by qualified individuals.

b. Observations and Findinas The inspector reviewed the records of five maintenance personnel selected at random from among the entire group. Although some training records were maintained on the MAPCON system and certain records were ,

maintained by an individual's supervisor, the official records were maintained by the Personnel Department in coordination with the Plant Training Department. Of those individuals reviewed, two were instrument technicians, one was an electrician, and two were mechanics. It was noted that, in the past, personnel were typically hired to perform one i job and then were trained to function in another. The current practice  !

is to hire personnel who have already received training and are qualified / certified in a certain skill from a technical college. The records of the individuals' skills and qualifications were compared with the licensee's job descripti,ns for a particular job classification. In i each case the maintenance personnel were determined to have received the i proper training and certification through work related experience, on-the job training, and/or specialized training from classes at a technical college.

As noted in Paragraph F1.03 above and F1.06 below, the inspector interviewed various maintenance 3ersonnel. All individuals interviewed were knowledgeable of the work tlat was being performed and the actions required to complete the job and return the equipment and/or instrumentation to proper working condition. Maintenance and Operations managers interviewed indicated that the maintenance personnel were experienced, knowledgeable, dedicated, and took pride in their work.

The inspector also interviewed the training coordinators for the maintenance organization. It was noted that, as was mentioned in Paragraph F1.01 above, continuing specialized training was coordinated through a local technical college and was generally available for those who requested the assistance.

c. Conclusions Based on interviews with licensee representatives and documentation of training and qualifications, the inspector determined that maintertance activities at the facility are being performed by qualified individuals.

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1 F1.05 Management Audit of Haintenance

a. Inspection Scope i

1 The licensee's programs for conducting management audits of maintenance activities and for identifying maintenance problems were reviewed to determine that problems were being reported and resolved and that maintenance activities were being audited.

b. Observations and Findinas The inspector interviewed various maintenance personnel including the maintenance manager, team managers, engineers, planners, technicians, operators, and mechanics to determine what program the licensee employed  :

to complete management audits of maintenance activities. Those interviewed indicated that no routine, formal, documented audit was conducted by management of the maintenance activities.

The inspector also interviewed these individuals to determine what '

program or system the licensee had in place to ensure that both major and minor maintenance problems would be identified and reported to management so that corrective actions could be taken. Those interviewed stated that the formal )rogram for reporting any type of a problem was the use of the " Red Booc" outlined in Regulatory Affairs Procedure No.

RA 107. Internal Reporting and NRC Notification of Unusual Occurrences, Rev. 6. dated March 17, 1994. Section 7.1 of the employee to report various types of issues to one' procedure requires ans imm upon discovery of the problem. The types of issues to be reported include process upsets, i.e., abnormal process conditions, unauthorized or unapproved operations or activities, and deviations from or inability to follow procedures. Once the problem was re>orted, the supervisor (or the o>erator) was required fill out a form, RA 1071, and place it in the " led Book." Copies of the form were to be distributed to Regulatory Engineering and to the Area engineer. The procedure tb o provides for a formal method of tracking the issue and closing it out. Although through this method of reporting a problem was formalized, it did not appear to give sufficient guidance for operations or maintenance personnel to report the minor, recurring problems that sometimes occur.

It appeared that, for minor issues, whether or not a problem was reported depended upon the initiative of the individual who noted it.

Other methods of problem reporting were also mentioned by those interviewed and included approaches from a technician reporting the issue to an engineer, maintenance planners reporting the problem to an engineer or a team manager, to the issue being brought to light from reviews of cost analyses of equipment maintenance and repair. Thesc types of analyses are typically done by team managers who report this l and other data to the maintenance manager in a monthly report.

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! Once a problem is re)orted, the licensee uses various means to correct the situation. If tie problem is of major significance, i.e., if it is

! directly affecting production, an investigation team is generally formed

7 to review the issue, determine the root cause, and develop corrective actions. If the problem is of lesser significance, the issue is generally assigned to an engineer to review and correct. The licensee also has Area Teams which have the responsibility to make improvements in production and safety. These teams may also be asked to resolve an identified problem in a specific area of the plant.

c. Conclusions Based on the interviews conducted with licensee personnel, the inspector determined that no formal management audit is conducted in the area of i maintenance. Reporting of maintenance problems can occur through the  !

use of the " Red Book" but generally occurs by other means. The licensee )

uses various approaches in response to problem identification from j forming an investigation team to assigning an engineer to review the  ;

issue and develop corrective action. <

F1.06 Surveillance Testing

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a. Inspection Scoof The inspector reviewed the licensee's program for conducting functional / ,

surveillance testing to ensure that the tests were being performed at 1 the frecuency delineated in the License Application, the procedures used providec adequate guidance, and the test results conformed to written requirements,

b. Observations and Findinas The inspector reviewed selected maintenance and surveillance procedures including the following:

e MCP-202046, Pressure and Differential Pressure Transmitters (Generic), Rev. 2, dated June 1, 1995 e MCP-202058. Limit / Trip / Interlock / Alarm Switches (Generic), Rev.1 dated June 27, 1990 e RA-108, Safety Significant Interlocks, Rev. 6, dated May 30, 1996 The inspector determined that the procedures contained adequate guidance to perform the required surveillance tests when used in conjunction with the forms and/or instrument data cards accompanying the PM and outlined in the procedures.

The inspector also observed surveillance testing in the chemical area of the plant and reviewed the instrument data cards and the results associated with those tests. The specific work observed involved the testing of instrumentation associated with nitrogen heater over-temperature indicator, the calciner scrubber level probe, the nitrogen ficw to the nitrogen heater indicator, and the "A" precipitation column level probe. The inspector noted that the technicians performed the

8 tests in accordance with procedure and the associated instrument data cards and the test results were within the ranges specified on the data cards. The tests were also performed within the frequencies prescribed by procedure. Interviews with the technicians involved with the testing indicated that they were aware of the scope of the tests to be

performed, were aware of the W0s and the special controls in place to i stipulate added safety precautions for the job, and were knowledgeable of the systems that were being tested.

Section 3.2.2 of the License Application specifies that the safety-related systems and components outlined therein are to be functionally tested at a prescribed frequency. The inspector reviewed the results of the surveillance testing of an representative sample of each group with an emphasis on those related to nuclear criticality safety and reviewed the frequencies of those tests as contained in the database of the MAPCON system. The tests were performed according to the procedure and j the tests were also performed within the prescribed frequencies.

) c. Conclusions i

Surveillance testing is being conducted within the specified frequencies as required by procedure, the procedures contain adequate guidance, and the test results are in conformance to written requirements.

F1.07 Calibrations of Equipment

a. Insoection Scope The inspector reviewed the licensee's program for conducting instrument calibration to ensure that the calibrations were being performed at the required frequency, the procedures used provided adequate guidance, and the calibration results conformed to specified requirements.

b. Observations and Findinas

The inspector reviewed selected maintenance and calibration procedures including the following

e MCP 202025, Panametrics 700 Moisture Analyzer Calibration, Rev. O, i dated June 22, 1989 I e MCP 202034, Solvent Extraction Aqueous Waste Monitor System 1, Rev. 8, dated April 21, 1994 e MCP-202035, On Line Monitor Calibration, Rev.10, dated May 9, 4

1996 e MCP-202037, GA 6M Criticality Alarm Calibration Rev. 6, dated May 9, 1996 The inspector determined that the procedures contained adequate guidance to perform the required calibrations when used in conjunction with the

9 for;ns and/or instrument data cards accompanying the PM and outlined in the procedures.

The inspector reviewed the results of selected calibrations with an emphasis on those related to nuclear criticality safety and reviewed the frequencies of those calibrations as contained in the database of the MAPCON system. The calibrations were performed according to the procedure and the results were within the ranges specified. The inspector also noted that these calibrations were performed within the prescribed frequencies.

c. Conclusions Instrument calibration is being conducted within the frequencies outlined by arocedure, the procedures contain adequate guidance, and the results of t1e calibrations conform to specified requirements.

F1.08 Preventive Maintenance of Equipment

a. Inspection Scope The inspector reviewed the licensee's program for conducting preventive maintenance to ensure that the PMs were being performed at the required frequency and the procedures used provided adequate guidance.

b. Observations and Findinas License Condition S-1 of License Number SNM 1107 requires that the licensee shall use special nuclear material in accordance with statements, representations, and conditions in the License Application dated April 30, 1995, and supplements dated May 11,18: August 4, 25:

and September 25, 1995.

Section 3.2.1 of the License Application requires that the following safety related systems and components will receive programmed maintenance: 1) air compressors: 2) emergency electrical generators:

3) fire detection and fire control: 4) natural gas valves: 5) nuclear criticality detection: 6) pellet carts: 7) pressure relief valves; and

8) steam boilers.

Section 1.4 of the License Application stipulates that when a measurement, surveillance, and/or other frequency is specified in License documents, the following applies: QUARTERLY frequency means four per year, with each covering a span of 115 days or less.

Maintenance and Calibration Procedure (MCP) Number MCP-108000, Rev. 2, dated October 21, 1993, requires in Section 4.7 that maintenance engineering enter all PM procedures and revisions into MAPCON and requires in Section 4.6 that crafts personnel perform preventive maintenance per work orders generated by the MAPCON system.

In the MAPCON system, PM 20451 stipulates the preventive maintenance to l

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i 10 be performed on the #1 North American Boiler, Equipment No. 65973, on a 3 month (quarterly) cycle.

The inspector reviewed the results of preventive maintenance performed for a representative sample of each group specified above and reviewed i the frequencies of that maintenance as contained in the database of the

, MAPCON system. In all cases except one the PMs were performed according to the procedure and within the prescribed frequencies. The exception noted by inspector involved that the 3 month PM for the licensee's #1 North American Boiler, Equipment No. 65973. A 3 month PM had been performed on June 21, 1995, under WO# 100297 (which was generated on May 11, 1995). However, the subsequent 3 month PM W0, WOf 109367, which was generated on September 14, 1995, was not completed until November 9, 1995. The time period between June 21 and November 9 is greater than .

the maximum 115 day interval allowed. When this issue was brought to l the attention of the licensee, a search of the records was made in an i effort to determine whether the PM was actually late or whether the W0 l had been closed out at a date much later than when the work had been 1 performed. No indication could be found that the PM was performed on time with only the WO being closed out late.

The inspector informed the licensee that failure to wrform preventive l maintenance of the #1 North American Boiler within tle frequency swcified was an apparent violation (VIO) of Safety Condition S-1 and Clapter 3, Section 3.2.1 of the License Application (VIO 70 1151/96 05-01).

c. Conclusions PM is being conducted within the specified frequencies and as required l

by the License scheduled for theApp #1 North American Boiler between the period of Junelic and September 1995.

VI. Management Meetings j

M1 Exit Interview On November 1, 1996, the inspection scope and results were summarized with licensee representatives. The inspector discussed in detail the routine program areas inspected, and the findings, including the violation for failure to perform preventive maintenance of the #1 North American Boiler within the frequency specified. Dissenting comments were expressed by the Manager, Regulatory Affairs in response to the characterization of the failure to perform only one PM within the swcified frequency as a possible violation. The manager indicated that t1e failure should be characterized as a non cited violation or as an Inspector Followup Item.

The licensee did not identify any of the materials provided during the inspection as proprietary.

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ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED I

Licensee Personnel

• R. Allen Manager, Reliability Based Maintenance

• L. Brazell, Team Manager, Maintenance i *J. Bush, Manager, Manufacturing

• R. Close, Team Manager, Maintenance

. *H. Doctor, Team Manager, Maintenance J

• J. Fici, Plant Manager

• D. Goldbach, Manager, Integrated Fuel Burnable Absorber (IFBA) and Rods

• W. Goodwin, Manager, Regulatory Affairs

• T. Jackson, Planner, Electrical Maintenance

• E. Richards, Planner, Mechanical Maintenance

*H. Ruhl, Team Manager, Maintenance

*C. Sanders, Manager, Nuclear Material Safety and Safeguards

• W. Ward, Manager, Chemical Manufacturing

• R. Williams, Advisory Engineer

*D. Young, Senior Maintenance Engineer 1

• Denotes those present at the exit meeting on November 1, 1996.

OtherPersonngl ,

i Other licensee employees contacted included engineers, technicians, mechanics, i operators, and security and office personnel.

NRC Personnel None INSPECTION PROCEDURE USED Procedure Number Title IP 88025 Maintenance and Surveillance Testing 0

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2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened Item Number Iygg Descriotion and Discussion 70-143/96 05 01 VIO Failure to perform preventive maintenance of the

1. 1 North American Boiler within the frequency  :

specified by Section 3.2.1 of the License Application.

Closed i Item Number Iygg Descriotion and Discussion None i

Discussed Item Number Iy2g Description and Discussion None LIST OF ACRONYMS CFR Code of Federal Regulations IFBA Integrated Fuel Burnable Absorber IP Ins pction Procedure NRC Nuclear Regulatory Commission MAPCON Maintenance, Planning, and Control (computer system)

MCP Maintenance and Calibration Procedure MR0 Maintenance, Repair, and Operations (storeroom)

1. Number PM Preventive maintenance REV. Revision RWP Radiation Work Permit SNM Special nuclear material SRE Safety related equipment VIO Violation W0 Work order L