ML20151H037
| ML20151H037 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/17/1988 |
| From: | Shymlock M, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20151H025 | List: |
| References | |
| 50-338-88-06, 50-338-88-6, 50-339-88-06, 50-339-88-6, GL-82-02, GL-82-12, GL-82-2, NUDOCS 8808010116 | |
| Download: ML20151H037 (44) | |
See also: IR 05000338/1988006
Text
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S 880g UNITED STATES
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- , NUCLE AR REGULATORY COMMISSION
REGloNil
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101 MAR 4ETTA STREET. N.W.
7 g ATLANT A.GEORot A 30323
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Report Nos.: 50-338/88-06 and 50-339/88-06
Licensee: Virginia Electric and Pcwer Company
Richmond, VA 23261
Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7
Facility Name: North Anna 1 and 2
Inspection Conducted: March 28 - April 1 and April 11-15, 1988
Team Leader: MAdv@ [ddn~ 0!/6'[8A
L. Watso t/ Date' Sig/ied
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Team Members: B. Breslau
R. Brewer
R. Croteau
T. O'Connor
R. Schin
M. Scott
M. Shannen
[ INM
Approved by:h. Shymiock, Cfief
/ DM
Dat'e Signed
Operational programs Section
Division of Reactor Safety
1
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l SUMMARY
Scope: This was a special announced Ooerational Performance Assessme.t (OPA).
The OPA evaluated the licensee's current level of performance in the area of
plant operations. The inspection included an evaluation of the effectiveness
of various plant groups including Operations, Maintenance, Quality Assurarce,
Engineering and Training, in supporting safe plant operations. Plant
management awareness of, involvement in, and support of safe plant operetion
was also evaluated.
The inspection was divided into three major areas including Operations.
Maintenance Support of Operations, and Management Controls. Emphasis was
placed on numerous interviews of personnel at all levels, observation of plant
activities and meetings, extended control room observations, and plant and
system walkdowns. The inspectors also reviewed plant deviation reports and
licensee event reports (LERs) for the current Systematic Assessment of Licensee
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Performance (SALP) evaluation period, and evaluated the effectiveness of the
licensee's root cause identification; short term and programmatic corrective
actions; and, repetitive failure trending and related corrective actions.
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i A review of past NRC inspections and reportable events indicated a troubled
performance history at North Anna, Weaknesses had been identified in the
- inservice inspection program, environmental qualification of equipment, ;
i procedural adherence, post maintenance testing, and procedure adequacy. .
j Several of these issues involved potential escalated enforcement actions, t
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l During this inspection, the NRC discussed the performance history with plant [
} and corporate management. The licensee's responses to these discussions and ,
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the results of the OPA indicate that weak areas had been identified by
I management and that significant actions had been taken to correct problems in ,
these areas, }
Long-term actions included the establishment of a Quality Maintenance Team l
concept; a substantial procedure rewrite effort; establishment of a Human >
Performance Evaluation System to systematically review personnel errors and
take appropriate programmatic corrective actions; Employee Involvement Teams; ,
and, analyses of the structure of site and corporate organizations including !
i redefining and reassigning responsibilities to enhance operational performance. l
! More recent efforts included additional emphasis on employee awareness of the [
need to follow procedure; an increased emphasis on individual ownership and !
- responsibility for quality work; additional guidance on post maintenance i
- testing and plans to provide further post maintenance test guidance upgrades; j
l reduction of equipment deficiencies; and new trending programs to evaluate :
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similar deficiencies and identify programmatic weaknesses. The licensee has !
l also added an onsite systems engineering group and plans additions to the
i maintenance planning staff. !
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In general, the licensee's programs in the areas inspected were found to be l
adequate with a number of particularly strong features. Management appears to !
be taking the appropriate actions to achieve improved performance. Weaknesses t
j were identifiec', in some programs as indicated below, The licensee committed to (
j evaluate these areas and take appropriate actions to enhance performance in !
these areas, Strengths and weaknesses are summarized below: i
i Strengths ,
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! In the area of Operations, strengths included:
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Control room operators were professional, att.entive, and knowledgeable, ,
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Maintenance coordination and tagging control were conducted outside the l
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, control room which greatly contributed to reduced noise levels and traffic i
flow in the control room,
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Equipment operator rounds consisted of a quantitative tour and a second I
- qualitative tour,
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Operations managers were aware of plant conditions, conducted frequent l'
) control room visits and plant tours and were actively involved in
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day-to-day activities.
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A number of Operations managers held Senior Reactor Operator (SRO)
licenses and had an extensive amount of North Anna control room operating
experience.
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Housekeeping plant wide was very good.
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Unit labels, color coding of unit procedures, and the new equipment
identification program were good.
The following strengths were identified in the area of Maintenance Support of
Operations:
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The scheduling and coordination of work activities between Operations and
l Maintenance appeared to be effective.
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The Quality Maintenance Team (QMT) program appeared to be a good approach
l toward higher quality maintenance. Maintenance personnel felt the QMT
l program had increased work quality (but wore uncomfortable performing
l their own Health Physics duties).
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Direct supervision at the job site and and communications between
technicians and foremen appeared to be good.
Strengths in the area of Management Controls included:
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The Inspector of the Day program provided quality control review of daily
activities.
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Effective and terse management meetings were conducted to evaluate issues.
Also, active management involvement in daily activities was observed.
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Managers had supervisors accompany them on tours and took immediate action
to correct undesirable conditions.
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Upper management conducted off-hour tours.
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An Employee Involvement Team Program appeared to be effectively involving
employees in resolution of plant problems.
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Performance evaluations were conducted on QMT inspectors every six months.
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Human Performance Evaluation System (HPES) reports on personnel error
events and corrective actions appeared to be thorough, timely and
effective.
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Responsible individuals and supervisors were present to present their
items to the Station Nuclear Safety and Operating Committee (SNSOC).
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Weaknesses -
Weaknesses in Operations included:
- Some control room instruments, such as instruments for normal cooldown
using the Residual Heat Removal System, were not in a periodic calibration
program.
- Shift turnovers for Shift Supervisors lacked a formalized checklist,
allowing for the possibility of incomplete transfer of plant status.
- Shift turnovers for Assistant Shift Supervisors were incomplete due to the
failure to review the opposite unit's Assistant Shift Supervisor narrative
log book, or Technical Specification action item log.
Weaknesses in Maintenance Support of Operations included:
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There was a backlog of approximately 7800 completed but not closed work
orders. The backlog was affecting the maintenance history files used by
the planners and the equipment history used for trending of repetitive
failures.
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The staffing for mechanical planners appeared to be inadequate to process
approximately 600 work orders per month and to close out the backlog of
completed work orders.
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Interviews with mechanical foremen and mechanics indicated that work
orders issued by Planning were sometimes incomplete.
Weaknesses in the Management Controls area included:
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The Temporary Changes / Procedure Deviations procedure contained weaknesses
in the generation, review, and control of procedure changes. A large
backlog of needed procedure changes existed due to weak procedure change
processing methods.
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The QNT program had not been assessed by QA since implementation.
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Trending of deficiency reports and work orders were not performed and root
cause analyses of equipment deficiencies were not performed in some cases.
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
- M. Bowling, Assistant Station Manager
- D. Cruden, Vice President, Nuclear Operations
"R. Driscoll, QA Manager, North Anna
- L. Edmonds, Superintendent, Nuclear Training
"R. Enfinger, Assistant Station Manager
- N. Hardwick, Manager, Nuclear Programs and Licensing
- D. Heacock, Superintendent, Technical Services
- 'G. Kane, Station Manager
"M. Kansler, Superintendent, Maintenance
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- R. Harowick, Corporate Manager, Quality Assurance
- A. Stafford, Superintendent, Health Physics
"J. Stall, Superintendent, Operations
- W. Stewart, Senior Vice President, Power
"V. West, Supervisor, Planning
- T. Williams, Manager, Nuclear Training
.
Other Itcensee employees contacted included technicians, Operation's
! personnel, maintenance and instrumentation and controls personnel, and
office personnel.
NRC Representatives
- J. Caldwell, Senior Resident Inspector
- L. Engle, Licensing Project Manager
- M. Ernst, Deputy Regional Administrator
M. Shymiock, Chief, Operational Programs Section
'J. Taylor, Deputy Executive Director for Operations (EDO)
- W. Troskoski, Regional Coordinator EDO
- B. Wilson, Branch Chief, Reactor Projects
- Attended exit interview ,
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2. Exit Interview (30703)
The inspection scope and findings were sumarized on March 11, 1988, with
those persons indicated in paragraph 1 above. The inspectors described
the areas inspected and discussed in detail the inspection findings. No
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dissenting ccenents were received from the licensee. Proprietary
information was reviewed by the inspectors, however, no proprietary j
information is included in this report.
Note: A list of acronyms used in this report is contained in paragraph 8. I
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Item Number Status Description / Reference Paragraph
- 338, 339/88-06-01 Open VIOLATION - Failure to follow !
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procedure for (1) audits of operator
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aids; (2) configuration control of the j
j casing cooling system; and, (3) !
revision of surveillance instruction
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and abnormal procedure to include ;
- Technical Specification revision on
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Mode applicability for containment
4 pressure - high. (paragraphs 5.a.(7),
- 5.b, and 5.g respectively.)
- 338, 339/88-06-02 Open UNRESOLVED ITEM - Determination of
j seismic qualifications for H and J ;
train emergency switchgear cabinets, !
! (paragraph 5.b)
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338, 339/88-06-03 IFI - Calibration of control room
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Open
instrumentation. (paragraph S.a.(5)) .
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! 3. Licensee Action on Previous Enforcement Matters (91701) i
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This subject was not addressed in the inspection.
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i 4. Unresolved Items ;
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Unresolved items are matters about which more information is required to
! determine whether they are acceptable or may involve violations or ,
j deviations. An unresolved item identified during this inspection is
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discussed in paragraph 5.b. ;
j 5. Operations (71707,71710,42700) !
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The inspectors performed extended observations of control room operations '
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I (including back shifts), shift turnovers, and reviewed applicable operator ,
j logs. The inspectors monitored Operations personnel performance, i
awareness of plant status, use of procedures, and the maintenance of !
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required station logs and status boards, ;
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1 Interviews were conducted with the Assistant Station Manager of Operations !
! and Maintenance (C&M) Superintendent of Operations, Shift Supervisor > !
! ($$s), Assistant Shift Supervisors (Assistant SSs), Control Room I
! Operators. Shift Technical Advisors (STAS), and various equipment l
[ operators. Random interviews were conducted with operators in the control
i room and equipment operators during system walkdowns, plant tours, obser-
l vations of surveillance and post maintenance testing, and tagging and '
j removal of equipment from service.
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The inspectors noted that many of the Operations managers hold Senior I
Reactor Operator licenses with an extensive amount of on-shift time, which !
greatly centributed to the Operations staff's confidence in management.
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a. Control Room and Local Plant Operations
(1) Control Room Demeanor
Control room conduct was a noteworthy strength. Licensed
operators were observed to remain within the work area as
required by administrative procedure, ADM-19.10, Limitations on
Licensed Personnel Movement, dated March 31, 1983, and
Regulatory Guide 1.114, Guidance On Being an Operator At The
Controls Of A Nuclear Power Plant. All licensed operators were
attentive to plant operations and alarm status. The attitude of
personnel was consistently professional. Discuss %ns were
limited to plant related activities.
Noise levels were low. The licensee had established a control
room environment which was conducive to attentive operation of
the nuclear units. The licensee had moved the maintenance /
planning functions out of the control room which resulted in a
quiet control room with a minimum number of distractions. The
control room was clean, uncluttered and well organized.
Access to the control room was controlled by administrative
procedure, ADM-20.11, Control Room Access, dated March 31, 1983.
The inspectors observed that personnel requested permission to
enter the work area, waiting out of the way until granted
permission to enter. The access control program was very '
effective despite the absence of any warning sign or pt scical
barrier.
No violations or deviations were identified.
(2) Procedural Compliance
The control room operators were observed performing a number of
procedures and evolutions. Licensed and non-licensed operators
had been instructed to follow procedures verbatim and if the
procedure could not be performed as instructed, a temporary
procedure deviation was to be processed and approved in order to
accomplish the task. Compitance with this instruction was ,
- videnced when reviewing the large number of temporary procedure ,
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deviations contained within the files located in the control
room. General weaknesses were noted with the temporary
procedure deviation process as noted in paragraph 5 d of this
report, i
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No violations or deviations were identified.
(3) Procedure Terminology versus Control Board Labeling
Procedure 1-AP-20, Operation From The Auxiliary Shutdown Panel,
dated January 21, 1988, was reviewed for consistent terminology !
between the procedure and the auxiliary shutdown panel. The i
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panels contained all instrumentation required by Technical
Specification 3.3.3.5 with the appropriate measurement range.
Additionally, all instruments were within the current
calibrattor, period, although several were missing current
calibration stickers. The following comments were discussed
with the licensee. Step 5.9.b of 1-AP-20 directed the operator
to adjust the steam generator power operated relief valve (SG
PORV) setpoints as required to maintain steam header pressure,
however, the instrumentation used was labeled "SG PRESSVRE".
The procedure did not caution the operator to ensure that the
auxiliary feedwater flow controller is set to the 100 percent
open position or that the SG PORV controller is set to the O
percent closed position before placing the local-remote switch
into the "LOCAL" position. The inspector noted that the
addition of operating bands or setpoints to the remote shutdown
panel gages could enhance the implementation of the control room
inaccessibility procedure.
No violations or deviations were identified.
(4) Alarm Response
Response to alarms and annunciators by licensed operators was
very good. The licensed operators were able to explain
conditions associated with all lit annunciators. Upon
annunciation of an infrequently received alarm, the licensed
operators were observed reviewing the annunciator response
procedures, directing the appropriate equipment operator to
verify local alarms, and taking corrective action as necessary.
The licensed operators appeared to be cognizant of the
evolutions occurring in the plant and their potential effect on
instrumentation.
No violations or deviations were identified.
(5) Status of Control Boards and Instrumentation
'/requent tours of the control room, including walkdowns of
control panels, were conductcd by the inspectors. The control
taards have very few work tickets outstanding. Work tickets
- ccated in the control room are only written for defective
switches or meters and not associated components. The licensee
was continuing efforts to bring the annunciator panels to a
black board condition.
Commensurate with these attempts, a small number of jumpers had
been installed to remove annunciators from operation which the
engineering staff had determined to be non-essential to the safe
operation of the plant and which required final implementation
of the associated engineering work request for removal. The
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jumpers were controlled by a jumper log, and licensed operators
were aware of the specific annunciators in a jumpered condition.
The inspectors noted that although control room operators check
strip chart recorders, entering date and time daily, the strip
chart time increments were not synchronized with standard time.
Synchronization of all strip chart recorders to standard time
could enhance plant operations and greatly assist the licensed
operators' examination and analysis of plant transients.
Calibration stickers were attached to almost all installed
meters, gauges and controllers. However, some of the indicators
had no calibration stickers and some existing stickers were
either illegible, blank or contained past due dates. The
control room operators, when questioned about these discrepan-
cies indicated that they believed that calibration stickers
were no longer required to be placed on control room indicators;
consequently, the discrepancies were not thought to be
significant. In February 1988, an Assistant Shift Supervisor
had sent a memorandum to tne I&C Supervisor requesting a status
of the sticker program. A response to that memorandum was under
development during this inspection.
The inspectors noticed that several calibration stickers
associated with the Unit 1 Residual Heat Removal (RHR) System, a
system required to be operable under the Technical
Specifications, had expired calibration datos. The licensee was
asked to verify that the indicators were included in a periodic
calibration program. The following indicators were submitted
. for licensee review.
Indicator Title
FT-132A and -1328 Component Cooling Water Flow
Through the RHR Heat Exchangers
TE-149A and -149B Component Cooling Water
Outlet Temparature from the RHR
Heat Exchangers
TE-150A and -150B Component Cooling Water
Outlet Temperature f rom the RHR
Pump Seal Coolers
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FS-131A and -131B Component Cooling Water Flow
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Switch from the Outlet of the
RHR Pump Seal Coolers
PT-1402 and -1403 Pressure Transmitters for
Automatic Closure of Valves 1700
and 1702 RHR Loop Suction
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Isolation
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i TE-1604 RHR System Heat Exchanger l
Inlet Temperature [
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TE-1606 RHR System Heat Exchanger l
Outlet Temperatu e !
PIC-1606 RHR Pump Discharge Pressure
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FT-1605 RHR System Flow Returning to i
Reactor l
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Ammeter RHR Pump Motor Current !
It was determined that only indicator PT-1402, PT-1403 and .
FT-1605 were included in a periodic calibration program. The l
remaining instruments were calibrated only if required following i
a maintenance repair or replacement effort. Consequently, the
instrumentation channels had not been recently calibrated and !
available records indicated typical calibration dates of 1976 l
through 1982. l
A brief review of other control room indicators revealed that
the instrumentation channels for numerous plant systems covered
by Technical Specifications were not included in periodic
calibration programs. A sampling of this list follows:
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Indicator Title
f
TI-103A Charging Pump Lube Oil I
Cooler Outlet Temperature
{
FI-105 Auxiliary Service Water Pump (
Discharge Flow {
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TI-150A Containment Sump Temperature i
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TI-105 Refueling Water Storage Tank
Recirculation Temperature
PI-156A Reactor Coolant pump A Seal i
Differential Pressure i
PI-121 Charging Pump Discharge
Pressure
TI-144 Non-regenerative Heat l
Exchanger Outlet Temperature !
TI-139 Excess Letdown Heat
Exchanger Outlet Temperature
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. PI-138 Excess Letdown Heat
Exchanger Outlet Pressure
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The licensee indicated that a commitment was made to :
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I periodically calibrate only that equipment listed in Regulatory
Guide 1.33, Appendix A, Section 8, in a 1981 response to a
Notice of Violation (338/81-07-14 and 339/81-08-14), (Licensee '
. letter serial number 385 dated July 10, 1981.) Appendix A was l
l reviewed and the above mentioned systems, including the RHR ,
- system, were not listed. However, for the RHR system, plant
operating procedures were identified which made use of the RHR
l indicators. For example, operations procedure 1-0P-14.1,
t Residual Heat Removal System, dated November 19, 1987, specified
' in step 4.1.14, that T!-1604 be used to monitor RHR system
! temperature increase when reactor coolant temperature is less
I than or equal to 220'F. Additionally, step 4.1.15 contained a
note specifying that component cooling water flow through the
4 RHR heat exchangers not exceed 8,900 gallons per minute. This
flow rate was monitored on flow transmitters FT-132A and
i FT-1328. Also step 4.1.16 specifies that TI-149A and TI-149B be
- monitored to ensure that component cooling water return
j temperature from the RHR heat exchanger remains less than or ;
equal to 200'F during system heatup. Procedure 1-OP-14.3, j
Swapping on Restarting Residual Heat Removal Pumps, dated
July 31, 1987, required in step 4.1.18 that RHR pump amperes be
i verified to be normal. Additional procedures may exist that
- utilize instruments not in a periodic calibration program. For
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example, an annunciator response procedure would be used to
respond to low component cooling water flow through the RHR pump
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seal coolers. Since flow switches FS-131A and FS-1318 are not
. periodically checked for calibration accuracy, the annunciator
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might not alarm when required and operator corrective action ,
might be delayed.
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! These procedural examples were discussed with Operations !
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Department supervisors. The procedural reliance on uncalibrated l
control room instruments was identified as a weakness. The '
i licensee committed to reevaluate the calibration program and ;
indicated that important control room indicators beyond those
listed in Regulatory Guide 1.33 would be included in the ;
periodic calibration program. Decisions on specific indicators j
would be made on a case by case basis, depending on their ;
importance to safety, usage during plant operations and existing ,
procedural requirements. The reevaluation of the previously 1
1 identified instrumentation for incorporation into the plant ,
i calibration program is identified as Inspector Follow-up Item ;
) 338, 339/38-06-03. l
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l No violations or deviations were identified. ]l
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(6) Communications
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Equipment operators, control room operators, STAS, and the i
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Assistant SSs appear to effectively connunicate, remaining
constantly aware of the status of the plant at any given time. !
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Interviews with the plant staff indicate that all individuals
appear to have a good working t tpport within each shif t. The
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plant staff further stated that the Operations management was
readily accessible and receptive to their concerns and ideas.
The 0,serations Superintendent was frequently seen in the control 1
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room, where he was able to observe shift operations and readily
communicate with the plant staff. Additionally, the Operations
! Superintendent attempted to meet weekly with the Operations crew '
l in requalification training.
] The $$s spent a majority of their time in the Technical Support
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Center (TSC) controlling the implementation of maintenance
1 activities. The day shift workload on the SS is very
- demanding. One SS stated that during the day shift, time was
- typically not available to tour the plant or personally observe '
control room operations. It should be noted that the TSC is
l located adjacent to the control room. The SS, however, is ,
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frequently to contact with control room personnel via telephone.
I In light of the SS's day-shift workload involving long absences ;
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from the control room, the licensee should evaluate the impact '
i of the SS's ability to direct the licensee response to a :
transient. !
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No violations or deviations were identified.
- (7) Logs and Records ,
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The inspectors reviewed the jumper log, control room operator -
log, the Assistant 55 log, safeguards operater log, night order !
l log, abnormal status log, and the SS log. The logs kept by the
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control room operators contained accurate information. It was !
noted during shift turnovers that the off going control room }
operator referred heavily to his personal notebook to inform the
- oncoming control room operator of evolutions and changes to :
plant status that occurred during his shift. The licensee
should review this practice to ensure that the control room
operator narrative log contains sufficient and necessary ,
j historical plant operating information. ;
During the review of the control room operators' narrative log,
the inspector found uncontrolled sketches which could have been
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misconstrued as operator aids. Administrative procedure
ADM-19.27, Control and Use of Operator Aids, dated October 29,
i 1986, delineates the requirements for sources of information
I which are posted to aid operator recall or note an abnormal !
! condition. ADM-19.27 also requires that "audits of the Operator
J Aid Log index will be conducted each calendar quarter and I
documented on 1-MISC-31." Miscellaneous Procedure 1-MISC-31, i
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Quarterly Operator Aid Log Review, dated August 21, 1986, states
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that "all Operator Aids in the areas of the station will be
surveyed on a quarterly basis (staggered one-third of the areas ,
, every month)."
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Further examination of the operator aid program required audits
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revealed that the licensee failed to perform the required l
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monthly audits for the first, second, and fourth quarters of '
1987 or the first quarter of 1988 as specified in ADM-19.27.
i This failure to perform the required attits is identified as an
example of violation 338, 339/88-06-01. In response to the
j! inspector's findings, the licensee removed the questionable
i sketches and performed an audit of the entire operator aid
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program. Several additional minor discrepancies were identified
i and corrected by the licensee.
! (8) Technical Specification Compliance
The licensee utilizes an Action Statement Status Log to control
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equipment and track Technical Specification action items.
Information contained in this book distir.guished between those
items which actually placed the plant into action statements and
! those which were "info," serving as a warning to the licensed
operators that additional actions may force the plant into an
action statement. Review of the log book is accomplished during
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shift turnover. These methods appeared to provide positive
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control over plant status.
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I No violations or deviations were identified. l
, (9) Shift Turnover Process
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The inspectors observed several shift turnovers for various l
watch stations inside and outside the control room. These l
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turnovers were accomplished efficiently and in accordance with i
i tJrnover procedures. As part of the turnover routine, each !
Assistant SS completed procedure MISC-35.2, SRO (Senior Reactor !
Operator) Shift Turnover Checklist, dated December 22, 1987, for i
the nuclear unit for which he had supervisory responsibility. '
Each Control Room Operator (CRO) completed procedure MISC-35.0,
CR0 Turnover Checklist (Medes 1-4), dated December 22, 1987, for
, his assigned unit. The checklists contained sufficient l
- information un plant status, parameters, system alignments and
abnorrealities to ensure that adequate turnovers occurred. The
checklists included references to any edor surveillances or i
- saintenance evolutions in progress. I
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Turnover weaknesses were nSted ir et eset Anistant SS l
cotepleted detailed plant status i N e ? nle uW while
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making a more general review ed '
site vnit's status.
While procedure MISC-35.2 adequ .4d t sing *a unit,
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it did not include requirements to review the equivalent logs on
the opposite unit including the opposite unit's Assistant SS !
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narrative log book, Technical Specification action item log, and ,
I reactor operator narrative log book. Consequently, the l
- potential existed for an Assistant SS to obtain a much less ;
detailed review of the opposite unit. With both Assistant SSs l
- in the control room this would not be a concern. However, one !
] Assistant SS frequently leaves the control room to perform tours !
] and the $$ is typically outside the control room. Consequently, I
J short time periods exist during which only one Assistant SS is !
<
in the control room. This individual may not be equally ;
familiar with the status of both units. This potentially i
'
'
disadvantageous situation was discussed with the licensee who l
subsequently committed to broaden the turnover requirements for !
Assistant $$5 to include both units. l
I
~
I
Both Assistant SSs reported to a single SS who primarily worked l'
in the TSC. It was noted that the SS did not utilize a turnover I
checklist. Exchanges of information between relieving SSs was
observed and found to be adequate. Typical reviews included the
same information contained on procedure MISC-35.2 such as the
2 Contrel Room Logs, Jumper Logs, and Shif t Orders. Although tne i
l observed turnovers were sati sf actory, the lack of a written l
j turnover checklist for the SS position is a weakness which !
should be corrected. A comprehensive checklist such as those !
available for the other operating crew positions, could preclude !
inadvertent failure to review important plant information prior i
to assuming shift responsibtitties. This concern was discussed !
'
j with the licensee who subsequently committed to promptly develop
t and implement a SS turnover checklist. :
1
J On-coming shift personnel who are stationed ovAside t,he controi
j room gathered for a briefing in the TSC shortly after completing i
i shif t turnover. The briefing was performed by the 55. The l
a observed briefings were effective in disseminating shift l
1 objectives promulgated in the Shi9 Orders and the Plan of the r
j Day, i
f Control room operators, however, did not participate in any [
i formalized sMf t briefing. Discussions with several control i
j room operators indicated that an operator specific briefing l
1 would be beneficial to their understanding of information s
! disseminated in the Shif t Orders and the Plan of the Day. The [
Operations Superintendent felt that operator turnover procedures j
i provided an adequate knowledge of proposed shif t activities. j
I
Integrated shift performance appeared to be satisfactory. l
1
No violations or deviations were identifieo. I
!
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-__ _-____ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _____________ __________ ____ _____ _ _ _ ___ ___ -__________-__ _____ __ _ _ ______
>
11
.
b. System Walkdowns
Two plant syttems, one for each unit, were walked down to assess the ,
adequacy of alignment procedures, housekeeping and configuration
l control. A Unit 1 system alignment was verified using Operating
- Procedure (OP) 1-0P-7.10A, Valve Checkoff - Casing Cooling System, ,
dated January 8, 1987. System configuration and drawing accuracy
were verified through comparison to drawing 11715-FM-01SB, Rev. 5.
The drawing and checkoff procedure were determined to bs accurate.
Procedure 1-0P-7.10A was last completed on February 5,1988. The
i
latest completed procedure was verified to be conpletely filled out,
'
initialed where required, and independently verified.
During the system walkdown, performed on April 12, 1988, two
discrepancies were identified and both were promptly corrected. The f
I tags for two Recirculation Spray (RS) test connection isolation
l valves 1-RS-102 and 1-RS-104 were found to be reversed. The valves l
are similarly configured and located in close proximity to each
other. Both valves were closed as required. The tags were promptly
returned to the correct valves. No other tagging deficiencies were
identified and all other system valves contained legible, easily
identifiable tags.
The second identified discrepancy resulted because Casing t'uoling
Tank recirculation pump 4A suction isolation valve 1-RS-105 was found
closed. The valve is required to be open in accordance with align-
rent procedure 1-0P-7.10A, The discrepancy did not adversely impact
the ability to recirculate the Casing Cooling Tank because the 4B
pump was operating and the 4A pump was secured. The Operations -
Superintendent indicated that the valve had apparently been closed on
April 9 or April 10 during system troubleshooting. The trouble-
shooting effort included swapping the operating recirculating pumps ;
and chiller units in accordance with procedure 1-0P-7.10, Casing
Cooling Subsystem of the Rectreulation Spray System, dated
October 20, 1987. The procedure did not require the normally open
pump suction or discharge valve to have their positions altered. l
However, the system operator was aware that discharge check valve l
1-RS-106 for pump 4A was stuck open as indicated by work request tag l'
WR 531252 which was issued on October 27, 1987. The operator shut
valve 1-R5-105 when he started the 4B recirculation pump to prevent ;
the existence of an undesired recirculation path backwards through '
the 4A pump and the stuck open check valve. This action precluded
the potential for tank bypass flow. However, the change in vahe l
position was not authorized by either procedure 1-0P-7.10 or l
1-0P-7.10A. Additionally, the operator did not obtain administrative l
approval for the alteration as required by the provisions of i
ADM-14.0, Tagging of Systems and/or Components, dated February 4, 1
'
1988. This failure to utilize the provisions of ADM-14.0 to alter
the valve line-up required by 1-OP-7.10 and 1-0P-7.10A is identified
as an example of violation 338, 339/88-06-01.
A Unit 2 system alignment was verified using procedure 2-OP-7.4A,
Valve Checkof f-Quench Spray (QS) System, dated March 19, 1587.
L
-.
12
Configuration and drawing accuracy were verified through comparison
to drawing 12050-FM-91A, Revision 15. The drawing and checkoff
procedure were determined to be accurate. Procedure 2-Op-7.4A was
last completed on October 29, 1987. The latest completed procedure
was verified to be completely filled out, initialled where required
and independently verified.
During the system walkdown, performed on April 12, 1988, two minor
discrepancies were noted. One drain valve associated with pressure
indicator PI-QS-203 did not have a local identification tag attached.
Additionally, leaking drain valve 2-05-20 did not have a work request
submitted. The drain valve had been wrapped in plastic and taped to
catch a small amount of contaminated leakage. Apparently the persons
identifying the leakage did not initially process a repair request.
The licensee submitted a work request promptly after completion of
the system walkdown. The discrepancies did not affect system
operability.
Equipment operators were assigned to make two rounds of their area of
responsibility during the course of their shif t. The first round
consisted mainly of a quantitative examination of plant parameters
within their area of responsibility. The second tour consisted
mainly of a qualitative examination of plant equipment. In addition
to the system walkdowns, the inspectors accompanied several equipment
operators on their tours of the safeguards equipment areas. In
general, all operators appeared to be familiar with the equipment,
its normal mode of operation and alert to equipment abnormalities.
During the course of tcuring the Units 1 and 2 safeguards areas, the
inspector observed lifting hoists and trolleys located on rails which
were attached to the top of the H and J train emergency switchgear
cabinets. At the time of the inspection, the licensee was not able
to provide analyses showing that the Itfting equipment was
seismically qualified. This is identified as unresolved item 338,
339/88-06-02. The licent.ee promptly removed the equipment and began
to perform formal calculations. The licensee has been asked to
provide the seismic qualification calculations and the plant
modification package, which placed the lifting hoists and trolleys on
the cabinets, to the NRC. The licensee placed the use of the hoists
and trolleys under administrative control requiring the equipment to
be removed upon completion of maintenance activities.
While touring portions of the secondary side, equipment operators
were observed isolating a portion of the condensate clean-up system.
The inspector noted that the operators did not perform the tag out in
the sequence specified on the tagging record. This discrepancy was
brought to the attention of the Operations Superintendent. Although
the activity observed had no ssfety-significance, the inspector was
concerned that tagging may be inappropriately conducted during
safety-related tagging. Discussions with the Operations
Superintendent indicated knowledge of deficiencies in the tagging
,__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
___________ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l
,
l
l
l procedure and procedure implementation. The Operations
l Superintendent provided the inspector with two Quality Control
Activity Reports (QCAR) which were issued for lack of compliance with
ADH-14.0, Tagging of Systems and/or Components. The corrective
action to the QCAR, which had not been completed by the licensee,
included a memorandum, to be issued by the Operations !
Superintendent, which required each shift supervisor to review with '
operations personnel the subject QCARs and the requirements of
ADM-14.0. The herations Superintendent indicated that the lecture
would stress the need for accurate tagging documentation and the
importance of aroper removal and restoration of equipment,
r
Items of noted strength observed during the plant tours included the l
color coding of unit procedures, the numerous signs reminding plant !
personnel of which unit they are about to enter, and equipment
labeling. These items help ensure that plant personnel are worxing
on the correct piece of equipment with the correct procedure,
c. Operations-Maintenance Interface
Maintenance work orders were reviewed to evaluate the adequacy of t
protective tagging, configuration control, SRO review and approval of
functional testing, independent verification and documentation. L
Operations used Maintenance Operations Procedures (MOPS) to remove
and restore major components from service for mainte'ance. The MOPS
referred to Operations Procedures which specified which Performance
Test (PT) must be run prior to returning the component to service.
Post maintenance testing (PMT) requirements were specified at various l
points during the WR and WC process, but final determination for ,
ensuring adequate PMT was made by the Shift Supervisor. A test i
coordinator was assigned to ensure that valve lineups, periodic i
testing, predictive analyses, and post maintenance testing were
completed prior to each mode change.
PMT requirements and guidance were undergoing revision due to
problems identified by the NRC and the licensee. Quality Control
l'
Activity Report number AR-N-86-1647 was written in December 1986
against improper post maintenance testing on several components. The ,
QCAR stated that the impreper testing indicated a potential program- 1
matic breakdown. Af ter several iterations of correspondence between
maintenance and quality assurance groups, the issue was escalated to ,
plant management. The new escalation policy had been implemented l
recently. Management involved other plant groups and decided to ,
develop and issue a new procedure to control the implementation of {
post maintenance testing. Procedure ADM-16.19, Work Order / ,
Maintenance Procedure Test Follower was issued February 29, 1938. l
The Test Follower supplements existing site maintenance surveillance
procedures by defining post maintenance testing activities. Although
the Follower appeared to assist the Shift Supervisor in coordinating
1 \
\ l
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l
I
14
l
l
l
l testing requirements, the effectiveness of the program could not be l
l evaluated due to the short period of time since implementation.
l
l
Open Maintenance Work Order (%'0) 178841 for working on the 1A
l charging pump was reviewed. The operations test block on the %'O had
l
been improperly marked as not required. This item was pointed out to
I the maintenance foreman and Shift Supervisor and corrected to reflect
that a test was required. The Shift Supervisor was aware of the need
for functional testing prior to returning the pump to service. The [
maintenance procedure used to perform the work did not specify which ,
PT was required. The charging pump operating procedure specified the l
required PT. Station records wore reviewed and the inspector
verified that the applicable PT had been run following maintenance on
the Unit I charging pumps during the past year. Reviews of other
completed work orders did not indicate any discrepancies in the i
completion of PMT requirements.
The licensee was in the process of upgrading maintenance procedures
to more clearly specify retest requirements and place the retest
requirements in an attachment to the procedure. Approximately 50
procedures have been changed to date.
In summary, the current method used to perfcrm post maintenance
testing it, cumbersome but adequate to ensure components are tested
prior to declaring them operable. Additional emphasis should be
placed on upgrading the post maintenance testing guidance.
No violations or deviatiers was identified.
d. Temporary Procedure Deviations
(
The administrative program by which temporary procedure deviations ;
are developed and approved, as specified in proceoure ADM-5.8,
Temporary Changes / Procedure Deviations, dated August 8, 1987, was
reviewed and found to be curbersome. Approximately 50 procedure
deviations were reviewed, the vast majority of which were annotated
indicating they should be incorporated as permanent procedure
improvements. However, the temporary change approvals were generally '
authorized for a single use only. The repetitive use of a procedure
necessitated the repetitive generation and approval of the deviation. .
Consequently, this method af fected the workload of the staff. In !
dddition, the Station Nuclear Safety and Operating Comittee (SNSOC) I
repeatedly received identical deviations for review. !
<
All of the deviations examined were enhancements which did not change
the intent of the original procedures or received prior SNSOC review. .
'
Consequently, as authorized by Technical Specification 6.8.3, they
were initially approved by two rembers of the plant staff with final
review to be perforned within 14 days by the SNSOC. Following ;
initial staff approval and prior to SNSOC review, a copy of the i
deviation is placed with the appropriate procedure in the control
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_ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
15
.
.
room files. Typically, this copy is not replaced with a final
approval copy af ter SNSOC review and Assistant Station Manager ,
approval. This is a potential problem because the $NSOC retains the
authority to make recommendations and comments on the deviation and
to promulgate special limitations on its use, as specified in
Attachment 1 of ADM-5.8. Consequently, the Operations Department
procedure files could contain copies of procedure deviations which do
not reflect the SNSOC approved version of the deviation.
A brief review was made to compare previously approved deviations l
held by the Operations Coordinator - Procedures to those deviations
on file in the control room. It was determined that several
deviations to procedures 1-OP-5.5 and 2-OP-5.5 were held by the
Operations Coordinator - Procedures but were not on file in the ,
control room. These deviations were annotated indicating that they
were appropriate for incorporation in a future permanent procedure
change. Their absence from the control room files could result in
performance of a procedure with previously identified enhancements !
omitted.
Most of the deviations are marked "permanent change required". These
deviations are forwarded for review by the Operations Coordinator -
Procedures to be incorporated in a future procedura revision in :
accordance with procedure ADM-5.4, Processing New and Revised
Frocedures and Deletion of Procedures, dated March 9, 1988. However, i
no index of deviations requiring permanent incorporation was ,
maintained. The lack of an index was disadvantageous because
approved deviations could be misplaced prior to incorporation. ,
'
Additionally, verification that all appropriate deviations had been
promptly incorporated into procedure revisions was extremely ;
difficult. For example, a deviation was approved en August 4,1986, '
and marked "permanent change required" for procedure 2-OP-3.3, Unit !
Shutdown Frvm Hot Shutdown Condition (Mode 4) to Cold Shutdown i
Condition (Modo 5) at 200 Degrees Fahrenheit. The procedure was l
revised in September 1986 but the deviation was not incorporated into '
the revision. As of March 30, 1988, a copy of the deviation remained
in the control room file. The deviation was either missed during the ,
procedure revision or remained in the control room file long after a [
decision had apparently been made not to incorporate the change into
a permanent procedure revision, t
The lack of a deviation index precluded an accurate quantitative
analysis of t,he backlog of procedures requiring revision. A review l
of the control room procedure file, the !&C Department procedure ;
file, and the file maintained by the Operativns Coordinator - '
Procedures indicated that a substantial backlog existed. The [
licensee had identified the backlog concern prior to this inspection. i
'
The Operations Coordinator - Procedures had been designated as the
Site Coordinator Procedures, a newly created position, for the l
purpose of better managing the procedure change process. The ,
l
i
L
16
centralization of the change process should improve efficiency and l
reduce the backlog. l
l
Another potential weakness of ADM-5.8 waa that deviations were not ;
evaluated for applicability to both units when initially approved. !
Consequently, t.he control room file for Unit 2, procedare 2-0P-5.5,
Filling and Venting the Reactor Coolant System With One or More Loop
Isolation Valves Closed, contained 3 "permanent change required"
l deviations, none of which were included in the Unit 1 file.
l Similarly, Unit 1 procedure,1-0P-b.5, contained a deviation which
was not in the Unit 2 file.
The review process for the deviations was also identified as
containing weaknesses. Presently, ths staff members have no
checklist to use in determining if a proposed change constitutes a
change to the intent of the original procedure. A generalized
definition of "change of intent" is contained in ADM-5.8. The i
procedure does not require applicable sections of the Technical ,
Specifications and Final Safety Analysis Report be reviewed prior to
'
determining if a proposed deviation effects the intent of a :
i pre-existing procedure. Additionally, proposed deviations are not !
evaluated to determine whether they change acceptance criteria.
'
I
modify hold points, decrease fire protection effectiveness, modify
independent verification requirements, change setpoints, or decrease
the effectiveness of the emergency plan. The licensee has previously [
recognized weaknesses in ADM-5.8 related to defining intent changes t
and a revision is under development. I
The weaknesses identified in the procedure change program were
discussed with the Operations 3uperintendent. Prior to this
inspection the licensee had developed and was reviewing a proposed
revision to ADM-5.8. The licensee committed to evaluate the r
inspection teams coments relative to procedure deviation control and I
to seek additional information from industry sources. Appropriate ;
modifications would be included in a revision to ADM-5.8 which was '
scheduled for issuance on May 1, 1988. j
Additionally, a complete audit of the control room procedure files ,
was initiated to ensure that all appropriate previously approved !
deviations were available to the staff. Any deviation copy which did '
not reflect $N50C review and management approval would be replaced
with a copy reflecting the approval. !
l
No violations or deviations were identified. l
l
e. Surveillance Testing ;
Selected surveillance tests were reviewed and/or witnessed by the !
inspector to ascertain that current written approved procedures were I
available and in use, that test prerequisites were met, that system j
l
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____ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
k
17
'
restoration was completed and that test results were adequate and in
compliance with applicable Technical Specifications.
The following tests were either reviewed or witnessed. Tests
witnessed are identified by an asterist.
l
- 1-PT-213.3, Valve IS! (Consainment Atmosphere Clean Up System) l
- 2-PT-64.4A, Casing Cooling System 2-RS-P-3A l
- 2-PT-64.4A.1, Casing Cooling Pump Bearing Temperature i
- 1-PT-82.2B, IJ DG Test (Simulated Loss of Off-Site Power) i
1-PT-34.2, Charging Pump Test 1-CH-P-1B, ,
Surveillances observed by the inspectors were performed in accordance (
with procedures and in constant communication with the control room i
staff. Prior to the performance of 1-PT-82.28, an infrequently
performed test, a pre-test briefing was held to review all required l
actions and desired responses.
It was noted that operators were signing prerequisites for verifying !
systems lined up per OP-1A, Pre-Start-Up Checkof f List, based on >
personal knowledge of system conditions but without actually looking
at the completed copy of OP-1A. The licensee comitted to issue l
guidance to Operations personnel with respect to what actions as e
required to verify this specific prerequisite. :
!
Examination of the Diesel Generator test file led to discussions with
the Superintendent of Technical Services on the subject of the .
licensee's implementation of Regulatory Guide 1.108. Periodic Testing
of Diesel Generator Units Used as Onsite Electric Power Systems at i
Nuclear Power Plants, as comitted to by the licensee in their !
Technical Specifications, The licensee was in compliance with the !
provisions of the Technical Specifications and Regulatory Guide ;
1.108. The inspector noted that the Itcensee performs post main-
tenance testing separate from the operability testing. Post t
maintenance testing which results in a f ailure is not considered a ,
valid failure if the failure was caused as a result, of the inability !
to correct the original problem. Failures as a result of unrelated !
problems, however, are considered valid fattures. !
!
No violations or deviations were identified. {
!
f. Overtime
The use of overtime by Operations was reviewed to ensure compliance l
with NRC guidelines and Technical Specification limits. NRC
l
guidelines on work hours include Generic Letters 82-12 and 82-02. !
The generic letters note, "in the event that unforeseen problems l
require substantial amounts of overtire to be used, or daring l
extended periods of shutdown for refueling, major maintenance or l
najor plant modifications, on r, temporary basis," that specific !
guidelines should be adhered to. These guidelines include extended
_ _ _ - - _ _ - - - _ _ _ _ _
.
-
18
work hours up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period. The generic letters
,
also recognize "that very unusual circumstances may arise requiring
deviativ from the above guidelines, such deviation shall be '
authorizeo by the plant manager or his deputy, or higher levels of
management."
The licensee's administrative procedure, ADM-20.3, Hours of Work,
dated November 5, 1987, was reviewed and found to adequately
implement NRC guidelines in this area. Review of the licensee's
"Deviation from Maximum Work Hours" records for 1987, however,
indicated that the maximum guidelines were exceeded by Operations
personnel approximately sixty times. The majority of the deviations ,
were for exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in seven days during outages and peak
vacation periods. The frequency of exceeding the maximum work hours
in 1987 indicates that overtime is being authorized quite often. The
licensee stated that operators were not remuved from training or
'
required to work on their days off in order to prevent other
oper.. tors from exct Jing the overtime guidelines. The licensee ,
stated that the overtime deviations were utilized to support
vacations and outages. Records for 1988 up to April 11, 1988,
indicate that the guidelines were exceeded four times.
No violations or deviations were identified,
g. Review of Abnormai Operating Procedures
The inspector reviewed five abnormal operating procedure s. The
following discrepancies were noted.
Abnormal procedure Ap-3, Loss of Vital Instrumentation, dated May 15,
1988, was established by the licensee to implement the action
Jtatements for inoperability of, among other instrumentation,
containment pressure - high. The action statement for containment
l pressure - high in Technical Specification Table 3.3-3 required that l
1 an inoperable channel be placed in the tripped condition within one
4 hour for operation to proceed. The inspector noted that the Mode
applicability of the procedure was only for Modes 1, 2 and 3. ;
Technical Specification 3.3.2.1 required containment pressure - high r
to be operable in Mooes 1, 2, 3 and 4. The inspector determined that '
Technical Specification 3.3.2.1 had been rev' sed to include Mode 4
for containment pressure - high in Amendment Nos. 84 and 71, issued
on August 25, 1986. Further review showed that in addition to the
AP, the 12-hour surveillance procedure for containment pressure -
high, LOG-4, Control Room Operator Log, had also not been changed to
include the Mode 4 applicability, iechnical Specification Table
4.3-2 required a channtil check every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for containment
pressure - high. The failure to ravise the Ap and the surveillance
i procedure to include Mode 4 applicability for contain ent pressure -
high is identified as an example of violation 338, 339/88-06-01.
,
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1
19
s
Review of AP-4.2, Malfunction of Nuclear Instrumentation
(Intermediate Range), dated May 1,1988, indicated that step 5.3.4 -
was in error in that the step directed the operator to jumper out <
only source range channel N32 if either of the intermediate range
detectors failed. The objective of the section was to ensure that
both source range detectors were disabled in the event a second s
intermediate range detector failed and, therefore, avoid actuating
the source range detectors at high power levels. An additional
discrepancy was observed in that the note af ter Step 5.1.1, stated, '
"Do not pull source range instrument fuses," yet step 5.5.3 provided
directions to return the source range fuses if they were pulled. The
licensee indicated that the procedure would be corrected.
The inspector also noted that various APs have actions tied to
Technical Specifications that specify specific time frames for the
action to be performed. The APs do not, however, provide the time
limitations. An exemple of this is AP-1.2, Continuous Rod Insertion,
dated August 27, 1986, step 5.4, which directs che operator to verify
reactor coolant system temperature greater than 541*F yet does not i
include in the "response not obtained" that the plant is to be placed
'
in Hot Standby if temperature is not restored within 15 minutes. The
inspector recommended that the procedures be reviewed to determine if
this information should be added to aid the operator in meeting the ,
Technical Specification time requirements.
The licensee's attention is also directed to an April 27, 1988,
letter from C. A. Julian, NRC, to W. L. Stewart, Virginia Power,
which indicated that deficiencies existed in AP-33, Reactor Coolant
Pump Seal Failure. AP-33 was written such that the operator could
not comply with Step 5.2 and could transition out of the procedure
prior to tripping the reactor coolant pump with the failed seal. .
Two operating procedures were also noted to be deficient. In !
addition to these items, the examiners subsequently determined that
procedure AP-22.7, Loss of Emergency Condensate Storage Tank, did
not contain provisions to fill and vent the firemain when the ;
firemain is used to supply auxiliary feedwater. The inspectors :
'
verified during the OPA that the license was also aware of the
deficiency in AP-22.7 and that the procedure was corrected,
i t
'
The licensee indicated that the APs were being reviewed and '
reformatted into the standard emergency operating procedure format i
- in the procedure upgrade program. These findings indicate that ;
i
additional attention to detail is warranted during these reviews. l
1
- 6. Maintenance Support of Operations (62700, 62702, 92700) !
'
{
j The inspectors reviewed station administrative controls; conducted [
interviews with workers and supervisory personnel; and reviewed work
'
,
packages, work requests, deficiency reports, the maintenance planning ,
process, the maintenance backlog and the prtventive maintenance program to
ascertain whether the licensee was implementing an eilective program t
('
,
20
relative to maintenance activities. The review included the maintenance
organization work procedures, maintenance programs and the interface with
Operations. Interviews were conducted with maintenance supervisors, the
planning supervisor, planners, he Operations Maintenance Coordinator
(OMC), and a number of craft 9, foreman and supervisors in the
mechanical, electrical, and ,nstrumentation and controls areas.
Interviews indicated an overall good knowledge and understanding of
maintenance duties and responsibilities.
There have been continuing improvements in the corrective maintenance
program at North Anna such as the procedure rewrite program, Quelity
Maintenance Team (OMT) training and increased management attention in
completing corrective -maintenance. The coordination of work activities
between Maintenance and Operations appeared to be vary good. Pihnning,
work history, repetitive failure analysis and root cause analysis were
,
considered to be areas of weakness and are being adversely affected by the
large number of completed but not closed work orders. The QMT program had
been initiated prior to the end of the last SALP period. The QMT program
appeared to be a good program, however, the instrument and controls and
electrical crafts had not completed training. The history of events
during the SAlp period indicated problems in the maintenance area,
however, it appeared that increased management attention had been placed
on improving ths quality of maintenance.
a. Planning Process
Administrative procedure ADM-16.7, Corrective Work Orders, described
the program for processing maintenance work requests including
identifying, prioritizing, authorizing, scheduling, assigning and
documenting associated activities. Work requests were processed and
approved by the OMC. Work orders were then generated by the various
maintenance planners.
The corrective maintenance process could be initiated by any site
employee. The work request form was a te part form. The upper
section was attached to the defective equipment and the bottom
section was forwarded to the OMC, Plant walkdowns and review of
deficiency reports indicate that the licensee was very efficient in
identifying equipment deficiencies.
The OMC screened all work request (WR) forms for accuracy and
completeness. Additionally, the OMC completed the WR form by
assigning priority, plant modo and some of the post maintenance
testing requirements. The work request was then entered into a
maintenance computer program and the following day the OMC verified
that the WR form was properly entered into the maintenance computer
program and approved the work request.
_ , _ - . __ _.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _
,
21
.
Next, the planning department reviewed the various WRs listed in the
maintenance computer files. The various disciplines in planning
determined responsibility, assigned lead trade and generated a work
order (WO) for each WR. The individual planners placed the assigned
WO in the lead trade planner's file who assigned the WO a title and
added a brief job description. Approximately 50% of the time, the
planner would go into the plant and review the WO to ensure correct-
ness in job description, component, train, location and type of
deficiency. If practical, the planner would then review and list
appropriate prints and schematics, component work history, suggest
procedures to be used, and verify availability o' parts for repairs.
If a Radiation Work Permit (RWP) was required the planner also
requested Health Physics assistance in advance to prevent delays. l
There were various programs used to coordinate maintenance
activities. The plan of the day (POD) listed those maintenance
1 activities that were to be performed during the course of the day.
The POD was used as a notification to the maintenance organizations
and Operations that various systems or components were to be worked.
There was a daily, 11:00 a.m. planning meeting where operational
needs were discussed. A weekly maintenance schedule was reviewed and
approved by the planning department and this scheduling document was
issued to coordinate work activities with the Operations Department's
periodic test schedule. There were also bi-weekly Electrical,
Mechanical and Instrument planning meetings to coordinate the
upcoming maintenance and preventive maintenance items with
Operations; resolve work orders on hold; and, call attention to
overdue maintenance. The OMC also maintained a list of Operation's
"Ten Most Wanted Maintenance Items" which aided in scheduling needed
maintenance activities. At the scheduled time, the WO was forwarded
to the appropriate maintenance foreman, the maintenance was performed
and the WO was sent bath to the planner. The planner reviewed the
completed WO, placed the appropriate data in the equipment history
file, and transferred the completed WO to the vault for permanent
record retention. '
i
j The scheduling of maintenance items and the maintenance interface j
- with Operations was not a problem and appeared to function
The OMC was an SRO licensed individual that directly
'
adequately.
interfaced with the Maintenance Planners and Operations Shift '
Supervisor. This greatly enhanced the licensee's ability to schedule
maintenance items.
It was noted during the inspection that an extremely large number of
completed W0s had not been reviewed by the maintenance planners and
also the WO data had not been entered into the equipment history
files. The backlog had been in the 8000 to 10,000 range for all
disciplines for the last six months. It was noted that approximately
- 600 WRs were submitted to the mechanical maintenance planners per
j month for review and processing. This workload had been effectively
t
5
.
22 l
overloading the mechanical maintenance planners. Another effect of
the large backlog of completed W0s was the inability to track
repetitive failures since the equipment history files were not ,
up-to-date.
The inspection team observed that due to the large workload of the ,
mechanical planners, that the W0s sent to the field did not always
contain all of the needed data such as complete job steps,
procedures, tools, drawings or technical manuals. Interviews with
maintenance mechanics and mechanical supervisors also indicated that
when a WO was issued from planning, the planning process was often
not completed. Work packages received from the Planning Department
were considered to be good for I&C and electrical, however, the
mechanical work packages were lacking. Various foremen stated that
they had to identify appropriate procedures, technical manuals and
prints. The mechanics further stated that they felt the procedures
were only 70 percent effective.
4 The licensee had implemented a number of items to assist in the
planning effort. Two contract planners had been added to the staff
within the last year. An additional clerk was hired by the
mechanical group to assist in completed package preparation prior to
'
forwarding to planning. Two crafts foremen (one Mechanical and one
i Electrical) had been hired by Planning to assist in the planning
effort. planning had established a two week review cycle for W0s
that have been planned but not performed. Craft, Operations, and '
Planning supervision participated in scheduled debriefs of incomplete
work and these discussions impact planned work.
Overall, the progra:a for planning work activities appeared to be
adequate. The coordination and scheduling activities between
Operations, Maintenance, Health Physics and other support i
organizations appeared to be very good. Weaknesses in the planning i
process included the large backlog of completed but not processed l
W0s, the lack of trending, the staffing of mechanical planners, and
incomplete work packages issued to the field by Planning. Actions i
being taken by the licensee should be effective in resolving these
weaknesses.
1
No violations or deviations were identified.
! b. Work Orders
i
Selected open and closed work orders (WO) were reviewed for adequacy, l
- detail, authorization, post maintenance testing, procurement, l
housekeeping, QA/QC review, root cause identification and closecut i
< inspection. Approximately 40 work orders were reviewed.
,
l
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23
Work orders that were generated by the planning department were
forwarded to the maintenance foremen. Maintenance foremen indicated
that they often added additional information to complete the work
orders prior to performance. The completed work orders reviewed were
adequately detailed, identified appropriate procedures in most cases,
identified problems and locations, and the job was properly
prioritized. The only area that appeared to need more detail was in
providing identification of drawings and technical manuals.
Procedures appeared to be adequate to ensure that post maintenance
testing was performed prior to returning the equipment to service,
however, referencing from one procedure to the next was cumbersome.
A section titled, Post Maintenance Check / Testing, was included in
certain work procedures and provided for work area cleanup, tag
removal, Shift Supervisor notification, RWP clearance, and post
maintenance test completion.
The Quality Maintenance Team (QMT) concept, discussed in
paragraph 7.d, appeared to have been fully implemented in the
Mechanical Maintenance Department where the quality control functions
were performed by QMT trained individuals. QC personnel were still
utilized for various hold points in Electrical and I&C Procedures.
QC also performed a random cursory review of completed work order
packages. Independent verification was performed as required by
various qualified individuals. The processes controlling QC hold
points, QC review, and independent verification appeared to be
adequate.
The inspectors noted that documentation of root cause for component
failures was not specific, was not always clear, and in some cases
was missing. A working program for tracking repetitive failures and
subsequent root cause analyses for the failures was a weakness
because of the large backlog of completed W0s that have not been
entered into the history files.
Overall, work order packages appeared to adequately document work
activities. Documentation of post maintenance testing and root cause
analysis were areas where added management attention was warranted.
No violations or deviations were identified,
c. Preventive and Predictive Maintenance l
l
(1) Scheduling
.
Scheduling was done by a maintenance scheduler, who made a I
weekly coordinated schedule each Thursday for all planned !
maintenance to be done during the next week (Friday to Friday). l
This schedule included performance tests (surveillances), i
preventive maintenance, and corrective maintenance. Mechanical, j
electrical, and instrumentation areas were all included and the j
scheduling was done with the aid of a computer system. Then the
weekly schedule was printed out in two formats, by
foreman / maintenance crew assignments and by equipment / system.
l
!
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
24
The weekly schedule included an estimated 10% overload for each
foreman and maintenance crew, to allow for possible job
deferrals due to unforeseen holdups with parts, Operations, etc.
Also a list of minor maintenance items (no work request
required) was used for fill-in work.
'
1 The weekly maintenance schedule was reviewed and modified daily ,
at the morning maintenance POD meeting. This meeting was i
attended by supervisors from mechanical, electrical, _and
instrumentation maintenance and also Operations and Health
Physics. Overall, scheduling of maintenance appeared to be very
well organized and conducted and is considered to be one of the
licensee's areas of strength.
(2) Scope
The scope of the preventive maintenance (PM) program for
mechanical and electrical areas appeared to be adequate. In
1987, system walkdowns by contractors were done to identify all
equipment and make PM program additions. As a result, about 30
PMs were added and many BOP components (including approximately
1500 manual valves) were added. Additionally, the PMs are under
continual review for updating, readability, initial conditions,
and post maintenance testing. In 1987, approximately 200 PMs
were revised. t
The scope of instrumentation PMs did not appear to be as
complete. Many supplemental gages for Technical Specification
equipment or balance of plant equipment were not included in the
PM program. For example, the calibration program did not
include some control board gages. This concern is discussed in
paragraph 5.a.(5) in more detail. ;
(3) PM Adjustments
PMs are routinely reviewed for both scope and frequency. Change
recommendations come f rom Mainter,ance and Operations, OERs,
design changes, and predictive analysis. The predictive
maintenance includes oil analysis, vibration measurements, and
motor operated valve analysis and testing (MOVAT). A checkmate
- check valve testing program is planned. Based on predictive
maintenance, about 20 changes in pH frequency were made in 1987
'
and about 10 changes in PM frequency were made based on
Maintenance or Operations recommendations. Repetitive failures
- of machinery have not been well trended in *he past and have not
been a substantial factor in adjusting PM frequencies. In one
case, the hydrogen and oxygen analyzers for the Waste Gas Decay
Tank (WGDT) were known to be affected by summer temperatures.
l
!
"
l
l
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25
1
I
l During the months of April-September, they would predictably
! drift out of calibration. However, no licensee action had been
l taken to increase the PM ' frequency on these safety-related
I instruments. The licensee committed to an increased PM fre-
! quency on these hydrogen and oxygen analyzers. Alv., the
licensee expressed plans for improved trending of Deficiency
l
Reports and machinery failures.
,
l (4) Overdue PMs
The handling of overdue PMs appeared to be adequate. Any ;
overdue PMs were so identified, and constituted less than 10% of ,
all PMs scheduled for the month. The overdue PMs were
highlighted in weekly and monthly reports, and appeared to be
L
aggressively pursued.
No violations or deviations were identified in this area,
d. Work Order Status
'
Work orders / requests were prioritized during staff meetings.
Identified non-Technical Specification related work is merged with TS
related work during these meetings. The daily meeting participants
l
were supervisory level with the OMC chairing the proceedings. .The
'
Planning Department provided information on material availability and
existing and projected work schedules. Equipment was returned to '
service based on operational needs.
Work order (WO) backlog for emergent work was not significant.
Overall, the three major departments (Instruments and Controls,
l Electrical, and Mechanical) trending showed a slight decline for W0s.
l The number of safety-related W0s that had not been processed by the
planners was approximately 1700. These numbers did not reflect W0s
that had been completed but not reviewed. This backlog is discussed
in paragraph 6.a.
A problem with voiding W0s was identified by the NRC in earlier l
l inspection findings and by the licensee. The licensee had changed
l the review process and the planners indicated that, at the present
l time, it was very difficult to void any work order if the work was
l not done. It now appears that many of the approximate 1500 W0s
l voided during 1987 were worked under other work orders such as
l previously scheduled preventive maintenance items. An example of
l cancelled W0s are valve repackings. The licensee stated that a large
number of scheduled repackings were voided due to difficulties with a
contractor who was to perform the work.
j No violations or deviations were identified.
,
!
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26
.
e. Training
Qualifications for performing the various assigned maintenance
activities were obtained by "on-the-job training (0JT)." After
performing a given task, a least one time, with a qualified indivi-
dual, the maintenance technician was signed off by his s;pervisor as
qualified to perform the task alone. Technical training was being i
given on and off site in specialized areas. A QMT class covering
welding was attended by an inspector. The instructor was well-
prepared and knowledgeable; and, training materials and course
content appeared excellent. The only retraining noted was general
employee training.
No violations or deviations were identified,
f. Management and Work Controls
Direct supervision appeared to be goed in that at least once per
shift the foreman would visit each job site to inspect work in
progress. There also appears to be good communications between tho
technicians and foremen. Overtime did not appear to affect work
quality. Minimum overtime is worked during non-outage periods and
overtime during outages is regulated by administrative procedures to
16 hrs / day not to exceed 50 hrs / week.
"
Various maintenance superintendents were interviewed in regard to
individual goals, ongoing improvements, planned improvements, staff
training, and identified weaknesses. The following goals were
identified during the interviews:
-
Limit contractors on site
-
Improve public perception
-
Enhance safety
-
Reduce minor injuries
-
Eliminate repeat findings ,
-
Reduce NRC violations to less than the Region II average
.
-
Reduce man-rem
-
No reactor trips caused by maintenance personnel l
-
Reduce non-outage corrective W0s to less than 500 ;
t -
Meet all commitment due dates
Ongoing improvements included:
-
More Quality Maintenance Teams ,
,
-
Reduced use of contractors i
-
Improved plant material conditions
-
Improved plant housekeeping l
l
,
l
.
27
The licensee noted that the following improvements had been made in
plant material conditions:
-
Steam leaks were being reduced by replacing old packing with a
'
new style of grapite packing (Chesterton) and by use of live
loading packing on selected valves such as the MSIVs.
-
Body to bonnet leaks were being reduced by ensuring use of
proper gaskets, using more graphoil type gaskets, and insuring
proper torquing of bonnets. ,
- Communications ~between North Anna and Surry maintenance
departments were improving because of monthly conferences with
corporate support organizations-
No specific problems were identified in material availability and
control, however, mechanical technicians stated that they
return incorrect matorials to stores about 20 percent of the,hadtime to
and
the I&C technicians stated that they had to return incorrect
materials about 15 percent of the time. Parts return was for various
causes. The inspector examined a sample of documentation of
completed work, but found no case where incorrect parts were
installed in the plant. This issue was brought to the attention of
licensee management. An additional problem in obtaining parts was
that some parts had to be ordered one day in advance from the store
house. This sometimes caused delays in returning equipment to
service and loss of man-hours due to waiting for parts.
Maintenance staffing levels were not perceived to be a problem with
the exception of the Planning Department which appeared understaffed
in the Mechanical Section. The need for additional personnel
adequately trend deficiency reports and W0s and to perform root cause
analyses had been recognized by the licensee. Addition of a full
time maintenance engineer for maintenance trending and root cause
analysis was planned. Eleven systems engineers were to be added to '
,
the technical support staff. The specific duties of the maintenance
engineer or the systems engineers had not been determined at the time i
of this inspection. l
Repetitive problems identified by the technicians were failures of !
the Boric Acid pump seals, charging pump seals, high pressure drain
pump seals and steam traps. Maintenance management was aware of
these problems and were taking actions to improve reliability of this
equipment, ,
1
'
No violations or deviations were identified.
g. Maintenance procedure Review
Maintenance procedures have been undergoing major revisions.
Complete procedure rewrites are being performed by contract
personnel. The maintenance group had established a new policy with
!
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28
.
regard to writing / rewriting procedures. Craft personnel are
involved in the procedure revision process. The licensee stated that
this policy stemed from problems with rewritten procedures generated .
by the procedure group solely. The organization and management of L
the procedure rewrite group has also been changed. The inspectors
examined one of the procedures, MMP-P-RC-1, Reactor Coolant Pump
(RCP) Seal Inspection, which had been rewritten by the procedure
group in the recent past and had been worked in January 1988. The
RCP seal procedure was deviated (required change) nineteen times
during the course of work which was a high number compared to
previous seal work using older procedures. The inspectors reviewed a ,
procedure group rewrite (draft) of the RCP seal procedure prior to '
the craft's review (the new policy had not been implemented). The
inspector noted three major points that had not been incorporated
into the draft from the previous deviations. The licensee committed !
to include the points.
Just prior to this inspection, the licensee had made the decision to
rewrite the major pump procedures in time to support an October 1988
outage. Forty-four procedures, affecting 250 pumps, were included in
the rewrite. Craft input for the procedure revisions was planned. ,
Maintenance personnel considered many maintenance procedures to be
ineffective due to being generic and requiring "write in" steps to ,
accomplish specific tasks. The "write in" steps of the procedure
could be generated at the job site, by a task qualified individual,
who was qualified based on "on the job training", The procedure did
not receive any further review until after the task was completed.
During the review of completed procedures in the various work
packages it was noted that "write-in" pro:edural steps were used.
Although no "write-in" steps were found that made intent changes to
maintenance procedures, administrative instructions did not appear to
be sufficient to prevent the use of "write-in" steps to change the ;
intent of the procedure. The licensee committed to enhance the t
! guidance on the use of "write-in" steps.
Another problem identified by maintenance personnel was that
individuals at different levels of the craft were allowed to sign-off
1 steps as "Not Applicable." The licensee should review this practice i
j to assure proper controls are in place, j
No violations or deviations were identified. l
h. Review of Licensee Event Reports (LERs) and Deviation Reports (DRs) <
Licensee's LERs for events that occurred during the SALP period were i
reviewed. From those, a total of six LERs were selected for further )
inspection effort. Two involved maintenance personnel errors and '
four others involved machinery failures. In addition, licensee's DRs I
were reviewed. From the DRs, two cases of repetitive equipment l
i f ailures were selected for inspection. The inspectors reviewed the l
, documents to determine the adequacy of the licensee's investigation,
corrective actions, and reporting.
- _
..
29 ,
(1) Unit 2 LER 86-14 involved a temporary jumper, placed 'in
accordance with an I&C maintenance procedure, which fell off
. resulting in a reactor trip. Human Performance Evaluation
"
System (HPES) Report 86-117, issued approximately two months
after the LER, documented a thorough review of the incident.
The HPES report made three recommendations to management. Two
of the recommendations had been implemented and the Licensing
Department Commitment Tracking System (CTS) was tracking the
third action until completed. Overall, the licensee's
' investigation and corrective actions following this LER appeared
to be thorough and timely. The HPES reports receive further
management review and distribution through the corporate
,
Operational Experience Review (OER) system. HPES was considered
by the inspectors to be a licensee strength.
(2) Unit 2 LER 87-018 covered an inadvertent 2J Emergency Diesel
'
Generator start during an electrical maintenance undervoltage
periodic test on the 2H emergency bus. An electrician had
J inadvertently entered a test signal in the wrong test cabinet.
4
A thorough HPES evaluation was conducted, and HPES Report 87-173
,
was written. This report included six recommendations to
j management. Completion of these items was being tracked by the
i
'
commitment tracking system as an HPES commitment, however, in
this case, the CTS incorrectly showed the LER as being completed
and ready for NRC closeout.
The licensee stated that plans existed to change the CTS this
year, to make it a more effective management tool. The current ,
CTS tracked commitments by category: 1.e. , LER, NRC Bulletin,
j INPO SOER, HPES report, etc. A particular issue was often
j implemented by several different commitments, but the CTS had no
cross reference and could not be sorted by issue. As a result,
an issue could be tracked under one or several commitment I
categories. To avoid duplication, this LER was closed out and -
the followup corrective actions tracked under the HPES report '
number. In the LER, the licensee made a commitment to the NRC l
.
to conduct an HPES investigation and to implement corrective ;
] actions. Since these actions were not completed, the LER >
2 corrective actions were in fact not completed or ready for NRC
J
closeout. The change to the CTS should correct the problem of :
i ability to show the correct status of each commitment.
l (3) Unit 1 LER 88-022 of January 8, 1988, described a manual trip of
1 the reactor due to the simultaneous loss of all three ,
- circulating water pumps. A similar simultaneous loss of all I
three circulating waters pumps had also occurred in August 1987.
i Although the circulating water pumps are not safety related,
their total loss challenges the plant protection systems,
requiring a manual reactor trip.
,
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1
30
.
Af ter the August 1987 occurrence, an engineering review could
not determine the cause. However, a potential cause was
identified to be the CW system protection circuitry. In the
circuitry, the opening of one of two condenser waterbox vacuum
breaker valves on two of four waterboxes will trip all CW pumps.
No report was written on this investigation. The LER indicated
that, to prevent recurrence, an evaluation would be done to
determine if surveillance on the CW system protection circuitry
could identify actual and potential equipment failures. This
commitment is tracked in the CTS, with a scheduled completion
date of August 1, 1988.
'
The inspectors found that the CW system protective circuitry and
vacuum breakers are not included in any regularly scheduled
surveillance, preventive maintenance, or calibration program.
Additionally, inspectors found that many balance of plant
non-safety systems similarly have no preventive maintenance done
on instrumentation and control circuits. The licensee stated
that they plan to test and evaluate the CW system interlocks
during the. upcoming outage.
- (4) Unit 2 LER 86-002 covered a reactor trip while in Mode 3 (hot I
standby) following a normal plant shutdown. When the source
range detectors energized, as designed, both detectors spiked
high causing the reactor trip. The detectors were replaced with :
new ones and an investigatior into the cause of the detector !
failures was conducted. The root cause of the failures was not
determined. The LER was then closed out in the CTS.
l
In the investigation report these possibilities were presented
for the failure cause:
'
a) Detectors came into service at overrange.
a) Electrical surge to the detectors.
a) End of expected life of the detectors. ;
1 With regard to the life of the detectors, a statement in the
I
investigation report was made that "due to the frequency of j
detector repl.4 cement, a valid operation time cannot be
determined." Since the licensee maintained records of detector
installation and plant operating history, this statement did not l
'.
seem to mske sense. As for the possibility that the detectors '
came into service at overrange, the LER stated that the source
range detectors came on as designed and intermediat' range
detectors (which generate the signal to energize the source
range) were correctly compensated to read accurately. In
'
summary, each of the possible causes listed in the report were
inadequately followed up or analyzed in the report. The
inspectors found that the author of the investigation report had
been a chemical technician who had been newly assigned to the
Safety E'gineering Department. The licensee stated that
engineering investigations, as committed to be done in LERs, are
now done by engineers.
I I
31
(5) Unit 2 LER 87-002 described an event where, with the plant at
100 percent power, the 1C charging pump discharge check valve
- stuck open following pump shutdown. This resulted in the loss
4
of r.harging and seal injection flow due to the backflow through
the IC pump. The cause of the check valve hanging open was
found to be excessive grit in the hanger bracket bushings which
were subsequently replaced. The discharge and recirculation
check valves on the Unit 218 charging pump and on Unit 1 10
charging pump were tested using the MOVATs checkmate system, and i
did not reveal any indications of valve degradation. Further
corrective action to be taken included developmr.nt of a pH
program for check valves used in critical applications, and
development of an Abnormal Procedure for loss of seal injection
and charging flow.
.
The abnormal procedure commitment was tracked in the CTS under
, the LER. The PM program commitment was tracked in the CTS under !
I
INPO SOER 86-03. The LER stated that a similar event occurred i
on the same valve on March 24, 1986. On that occasion, a work
request was submitted but the work order was cancelled because
the valve appeared to function properly after being seated.
In interviews with mechanical maintenance supervisors who had
been at the plant for many years, the inspectors were told that e
the grit in the valve was an isolated occurrence. No similar :
grit had been seen elsewhere in the charging system, during i
various inspections. This LER did not seem to adequately
describe followup concerns or inspections for grit elsewhere in ,
the system, nor did it seem to fully discuss followup testing of I
all other check valves in the system. It appeared to the ;
'
'
inspectors that a more thorough followup engineering investiga-
tion of this event should have been done.
(6) Unit 2 LER 87-012 reported a failure of Type "C" local leak rate
,
testing by three containment isolation valves. These valves
1
provide isolation for the condenser air ejector discharge when .
it is diverted to the containment, l
,
'
This LER was submitted later than the required 30 days from the
time of the event (event date August 31, 1987, LER date l
a October 14, 1987). The stated reason for report lateness was
procedure inadequacy. The acceptance criteria for the procedure
'
did not require a deviation report for "as found" leak rate
greater than the required limit of 0.60 La. Also, the LER did
not contain a licensee contact name and telephone number.
l The engineering investigation report that was done subsequent to
} this LER found that the cause of valve leakage was not debris,
- as stated in the LER, but instead was an incorrect testing
method. Pressure had been injected between two valves in
4
4
_- . .. .-.
h
k
a
32
-
,
series, which tested one from a direction in which it was not '
i designed to hold the test pressure. A corrected test method was i
used and the valve did not leak. The inspector found this l
s analysis acceptable, except for one point. If the testing :
procedure was faulty, how did this valve pass previous Type C [
testing? The licensee investigated this, and found that on the
previous test, the same failure had occurred. An engineering ,
analysis had been done, and a temporary change to the test [
procedure had been written. Apparently, since then the ;
procedure had not been permanently changed and the temporary
l change had been lost. The use of temporary changes to
1 procedures, instead of needed permanent changes, was found to be
an overall area of weakness for the licensee, and is discussed [
in paragraph 5.d. i
1
Rev. I to this LER was issued to cover the results of the i
engineering investigation and the revision of the test !
, procedure. Based on this onsite inspection, Unit 2 LER 87-012 !'
Rev. 1 is closed.
i
(7) A review of the DR log revealed a series of repetitive failures I
I
of oxygen and hydrogen analyzers for the Waste Gas Decay Tank j
(WGOT). The safety function of these monitors is to alarm if l
oxygen and hydrogen levels increase toward an explosive mixture, j
During the period of April-September 1987, ten DRs were written [
for operational problems with these analyzers. In each case, !
the instruments were recalibrated and returned to service. The i
instrumentation maintenance supervisors indicated that the
problems with these analysers were temperature sensitivity and i
being prone to drift. The analyzers were located in the base- f
i ment of the fuel butiding, which was not air conditioned. '
During warm weather, it was not unusual for the analyzers to
]
,
-
. drift out of tolerance prior to the scheduled PMs (monthly r
functional test and quarterly calibration). The supervisors
stated that these analyzers were also used in other industries, !
where calibrations were typically done more frequently, ;
sometimes weekly or even daily. Increasing the calibration
2 frequency of the WGOT oxygen and hydrogen analyzers was con- l
I sidered by these supervisors,. but was not done. The licensee ,
j made a commitment to increase the calibration frequency of these
l analyzers to at least monthly. The calibration frequency should I
- be based on performance. l
The oxygen and hydrogen analyzers have a built-in capability to !
4 automatically perform a daily calibration check. For the oxygen i
l channel, this would consist of sampling a gas containing zero f
I
percent oxygen for 15 seconds, then sampling a gas mixture l
.
containing 5 percent oxygen for 15 seconds. Zero and five j
i percent are the low and high ends of the recorder scale which is :
} located in the control room. Inspection of the control room !
l
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,
recorder chart revealed that no daily calibration checks were
recorded for the previous two days. Review of previous charts,
in the records library, revealed that only three daily calibra- ,
tion checks (all on the oxygen channel) were recorded from the f
last week in January through the first week in March 1988. The
daily calibration check had not been operating. Reviews of :
' control room logs and interviews with operators revealed that
the log sheets did not describe how the operator should inspect
and record the daily calibration check. No standards were l
provided and the operators did not understand that there was a l
'
J
daily calibration check feature, wherein the actual readings of
0% and 5% were important. The hydrogen channel check feature
was found to have never been hooked up. The licensee indicated
to the inspectors that the oxygen channel calibration check
feature would be repaired, control room logs would be changed to [
provide adequate instructions to the operator, and operators
would be trained in proper reading and recording of the daily [
calibration check.
1 The vendor had recommended replacement of the existing oxygen
i and hydrogen monitors with newer models, which are less
i temperature sensitive and less prone to drifting. The
- instrumentation maintenance supervisors have submitted a
purchase request for new oxygen and hydrogen monitors.
(8) The DR review also revealed a history of repetitive failures of
radiation monitors during 1987. The instrumentation maintenance
supervisors indicated that these were Kaman Science brand
,
monitors. In response to continual problems, one monitor had
been taken out of service for five weeks in late 1987 and during
'
that five weeks Instrument technicians worked with a vendor j
representative to develop a permanent fix. A field change was
developed and implemented, which appears to have substantially (
improved the reliability of that monitor. The maintenance i
supervisors stated that the other radiation monitors were being
l modified to incorporate the new field changes.
In reviewing DRs for repetitive failures, it was determined that
1 the licensee had not done trending of DRs. The licensee l
, committed to begin trending DRs so that repetitive failures
t
would be noted and would receive management attention. It was
also noted that trending of work orders for repetitive machinery
failures was not effective. A major contributing factor was the
-
large backlog of completed work orders not entered into the
.. machinery history.
(9) A deficiency report and a maintenance work order review revealed ,
a history of repetitive failures of containment isolation valves i
, to pass Type C testing. The valves reviewed were IHV-MOV-100A
'
and -1008 and are the containment purge isclation valves. It
was noted in the work order packages that the valve seats were
i
34 ,
.
greased and then retested after initial failure. A detailed
review was performed by the inspector and discussions with
various technicians disclosed that the greasing of the seat was
for aiding in seal adjustment and for seal removal after
extended periods. In this case it appeared that lubrication of ,
the valve seating material was an acceptable practice and f
enhanced valve performance. l
t
Minor deficiencies in the LERs reviewed we:e noted by the
inspector and were pointed out to the licensee. The inspector
also noted that a new LER format developed by the licensee in
late 1987 appeared to have improved the quality of the LERs, in
that the new format leaves less opportunity to omit required I
information.
The inspectors notea that five of the six LERs reviewed included l
commitments for follow-up investigations. Yet every one of !
- these LERs stated that no supplemental LER was expected to be
submitted. Ir. most of the followup investigations, additional l
information such as a cause of the event or corrective action l
) was determined. But supplemental LERs were not submitted. The
d licensee indicated that HDES and engineering investigation '
I reports would be reviewed in the future for the need to submit
supplemental LERs.
In contrast to the high quality found in the HpES reports, the
inspectors noted that some engineering investigation reports
were not written (i.e., August 1987 trip of all CW pumps) or ,
poorly done. Further, it was noted that HPES reports were !
distributed through the corporate operational experience review '
j
'
(OER) program, where they got additional review and
dissemination. Engineering reports were not distributed through l
corporate OER. The licensee stated that future engineering i
investigation reports would be of better quality and would be
distributed through corporate OER. ,
'
i
] No violations or deviations were identified. ;
7. Management Controls (30702, 40700)
7
,
)
The organizational structure was reviewed to determine that it was I
l prescribed by corporate policy documents and standards; that its functions
i were adequately defined by administrative procedures; and, that staffing
and staffing plans appeared adequate to fulfill the chartered roles.
- The status of implementation of major organizational functions was
'
determined by review of procedures, review of records, interviews and
,
discussions with licensee managers, supervisors and staff personnel inside
i and outside the departments of interest.
)
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.- _ - _ _ _ _ _ - _ _ _ _ . _ _ _ _
35
a. Station Nuclear Safety and Operating Committee
The activities of the onsite safety review committee, the Station
Nuclear Safety and Operating Committee (SNSOC), were reviewed to
determine if the committee was functioning as required by the -
'
Technical Specifications (TS), was providing adequate interface with !
various plant disciplines, anc was performing adequate safety !
. evaluations. [
!
In addition to the requirements delineated in the TS, the SNSOC
, activities are controlled by administrative procedure ADM-1.1. To
i review the committee's activities the inspector reviewed the
following SNSOC documentation:
'
1 -
ADM-1.1, Station Nuclear Safety Operating Committee, dated
1
June 16, 1987 i
i
-
Nuclear Operations Department Administrative Standard, .
i Management Overview, N005-ADM-03, Rev. 0
1 -
N005-ADM-06, Organization, Responsibility and Interfaces, Rev. 0
-
ADM-1.0, Station Organization and Responsibility, dated July 9, ,
!
<
1987
-
j
-
Selected meeting minutes ,
! !
- In addition, the inspector attended SNSOC meetings, interviewed
' '
members, and alternate members.
The SNSOC holds meetings usually on the order of once a month. More
frequent meetings or special meetings are held as needed. There is
good member participation during the meetings and evidence of strong
1 management control. The committee encourages outside participation,
1 This was evidenced by participation by individuals and their ,
j supervisor who were initiating a permanent procedure change, i
.
deviation or other administrative action. These individuals were !
l required to present their issues and resolution at the $NSOC ;
< meetings. :
i
'
The SNSOC appears to be accomplishing their mission and performing .
adequate reviews and safety evaluations. The use of outside I
'
individuals and their supervisors is considered an effective
enhancement, promoting clear communication among all parties.
1
! No violations or deviations were identified,
i 1
9 b. Plant Status Meetings ;
j i
'
Various plant status meetings were attended to determine whether l
day-to-day plant activities and planned future activities were being '
j adequately disseminated to the applicable plant staff.
i
1
! :
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-. ,_ - --. .
. . .
- -. _- -_ -- .
..
36
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.
,o review the plant status meetings, the inspector attended selected
'*
,
daily plant meetings. The licensee's daily plant status meetings l
consisted of the following:
,
-
8:15 a.m. Executive Management Meeting l
!
-
11:00 a.m. planning Meeting ['
-
3:00 p.m. Plan-of-the-Day meeting
,
There appeared to be good interface between plant groups and good !
!
participation by personnel in plant status meetings. The various
status meetings provided a discussion of plant conditions and ongoing
planned maintenance and/or testing activities. There is good
, management control at the meetings and adequate multi-discipline
attendance including the security personnel.
The inspector noted that the Superintendent of Operations and the !
l Superintendent of Maintenance conducted daily tours of the facilities
! and that senior management conducted random assessment visits during :
! off normal working hours. The inspector observed that during these
l tours the managers take on-the-spot, immediate, and effective actions
l to have problems resolved and more importantly bring it to the !
i
attention of the individual involved. It was also noted that these
l managers frequently had their next lower tier supervisor acconipany '
,
them during these tours, which reinforced what managemenc considered ,
I to be an acceptable plant standard. L
!
l The licensee appeared to conduct effective and terse management !
l meetings to evaluate issuss coupled with active management involve-
ment in daily activities. ,
No violations or deviations were identified.
l c. Nuclear Safety Engineering
1 ;
l The activities of the Nuclear Safety Engineering (NSE) group were i
reviewed to determine if they were functioning as required by the TS, !
were providing adequate interface with various disciplines, and were i
maintaining surveillance of plant activities to provide independent '
verification that these activities were performed correctly and that
,
human errors were reduced as much as practical. l
In addition to the requirements in the TS, the NSE activities are l
delineated in ADM-1.2, Nuclear Safety Engineering, dated February 3,
1988. To review the group's activities the inspector interviewed the
,
4
NSE Supervisor, several engineers and reviewed the following I
administrative procedures:
l
l
l
l
l r
. .
>
37
-
ADM-1.2,. Nuclear Safety Engineering, dated February 3, 1988 i'
- ADM-5.3, Review of Procedures, dated March 10, 1988
-
ADM-6.19, Processing of Significant Operating Experience Reports
(50ER), dated September 11, 1986 .
ADM-16.17 Human Performance Evaluation System (HPES), dated
i
-
May 28, 1987 ,
-
ADM-16.14, Commitment Tracking Program, dated August 20, 1986 '
-
ADM-15.0, Nonconformance Reports, dated May 29, 1986
-
ADM-6.14, Control of Engineering Work Requests, dated March 31,
- 1983 t
ADM-3.9, Evaluation for Potential Unreviwwed Safety Questions,
'
'
-
March 19, 1987 .
'
1
1 The inspector determined from the above reviews and interviews that
NSE had 16 degreed engineers, of which, seven are certified STAS; six
'
,
are qualified to be certified STAS, and two are to be placed in the ;
'
next certification class. This group appeared to be providing j
adequate on going reviews and assessments of plant operations.
,
Additionally, the NSE provided adequate reviews of INPO Significant ;
Operating Experience Reports, industry events, NRC I&E Notices and -
j Bulletins, and Licensee Event Reports.
The NSE was also responsible for coordinating the Human Performance
Evaluation System (HPES) program. A HPES pilot program was imple-
J mented onsite in 1985. The program was designed to uncover specific
adverse administrative practices and human engineering hardware
deficiencies which contribute to inappropriate actions. This program :
I allowed anyone to report a potential problem that may affect safe !
t
4 operation, reliability, availability or an inappropriate action
'
concerning personnel performance. The program was formalized in 1
i 1986. A review of HPES reports and resultant actions indicated that t
this program appeared to have a positive impact in reducing human ,
errors in plant operations. The HPES program is considered a
strength. l
i ,
,
j No violations or deviations were identified. [
i
1 d. Quality Control 1
!
The inspector conducted interviews with the Manager Quality
i Assurance, supervisors and inspectors. He also reviewed the
1 following documents
a r
-
Nuclear Operation Department Policy Statement (N00PS)-QA-01, !
i Quality Assurance / Quality Control, Rev. O j
-
NODPS-QA-02, Corrective Action, Rev. 0 '
-
Nuclear Operations Department Standard (NODS)-QA-01, Corrective !
Action, Rev. 1 l
- N005-QA-02, Audits, Rev. 1 t
j -
N005-QA-03, Inspection / Surveillance, Rev. 0 (
l
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VEP-1-5A Topical Report, Operations Phase QA Program l
. !
f
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> I
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38
.
-
Quality Assurance Organization Policy Statement (QAOPS) -2.3, i
Corrective Action, Draft
-
Quality Assurance Organization Standard (QA05)-2.3, Corrective
,
Action, Oraft
1
- Quality Assurance Department Instruction Nuclear (QADIN) A 4.0, ,
. Certification Program for Inspectors Assigned to the Quality
Assurance Department, Rev. 1 , i
QADIN C1.0, Surveillance Program Administration & Operation,
'
-
.
Rev. 0
- QADIN Guideline 2C.1, Inspector of the Day Guideline, Rev. 0
-
Audit Schedule
'
-
Surveillance Schedule
-
Completed Audit Reports
-
Quality Maintenance Team (QMT) - ADM-2.11, dated February 12,
1988 L
The inspector noted from the above interviews and reviews that the [
, licensee had determined that the audit and surveillance groups spent
approximately 60 percent of their time performing collateral tasks, ,
'
detracting from their basic responsibilities. Although it had not
i prevented QA from meeting its audit schedule, the collatsral tasks
! had caused issuance of the audit reports to be delayed. During the i
t
first quarter of the yea *, the QA surveillance group missed several '
- scheduled surveillances. Further review indicated that this was due ,
to special surveillances being implemented in response to industry-
wide INPO and NRC issues. A review of the missed scheduled surveil- F
lances indicated that no TS requirements were impacted. The licensee
is restructuring responsibilities within the QA department to allow
4
the audit and surveillance personnel to devote the majority of their
'
i time to their auditing and surveillance responsibilities.
i The licensee utilized an "Inspector of the Day" (IOD) program to
- provide daily coverage of plant activities, seven days a week. The
100 was not assigned any other responsibilities on their "duty" day.
'
,
Their responsibilities included walkdown of areas of management
interest, observation of special evolutions, observation of repairs ,
,
or modification activities, and informing the SS and cognizant l
J supervisor when violations or unsafe conditions were noted. This
program was considered a strength.
J
'
Quality Maintenance Team (QMT) concept was implemented in 1986. The
! licensee's goal is to develop 18 teams. These teams will perform l
'
their own QC inspection and radiological control functions. The ;
intent is to build quality into the maintenance activity. The team
building was approximately 70% complete. The mechanical maintenance l
, i
teams were the first groups to be formed and the QMT program is '
expanding to include the electrical and I&C disciplines. Maintenance
j personnel stated they felt the QMT program had increased work
i quality. However, the three mechanical maintenance QMT members who
were interviewed all stated they felt uncomfortable performing their l
l
1 own health physics duties, particularly on more complex tasks.
5
J
1
- - - - - _ _ .
39
The licensee appears to have devoted many hours toward developing
this program. They have provided designated personnel from
Corporate, Surry, and North Anna to form a Quality Managing Steering
Team and a Quality Managing Working Team. These teams meet
frequently to discuss problem areas and explore possible
enhancements. This program was considered a strength. A note worthy
concept employed is that the certified QMT inspector will be
administered a recertification performance inspection approximately
every six months. The QMT inspector will perform an inspection i
activity while being observed by a QC department inspector, as '
required by QADIN A 4.0 Rev. 1, Section 5.6.
However, the inspector noted one QMT program area considered to be a
weakness. The QMT is required to perform a pre-job briefing and a ,
post-job briefing. The QC department appears to be attending only
the pre-job briefings. No QC observations were made during the post
maintenance briefings to ensure that the team is addressing the
quality aspect or problems encountered.
In additinn, considering the licensee's high expectation of the QMT
program, there hasn't been a QA assessment conducted since the
program was implemented. This is considered a weakness in that the
licensee has not assessed that the actual mechanics of the main-
tenance activities are providing the quality of work that is
perceived by management.
No violations or deviations were identified.
8. List of Acronyms ,
BOP Balance of Plant
CR0 Control Room Operator :
CTS Commitment Tracking System ;
DR Deviation Report
EDO Executive Director for Operations
HPES Human Performance Evaluation System
HP Health Physics
ISC Instrumentation and Controls
IEB Inspection and Enforcement Bulletin ;
IEN Inspection and Enforcement Notice l
IFI Inspector Followup Item !
INPO Institute of Nuclear Power Operations !
LER Licensee Event Report :
MOVAT Motor Operated Valve Analysis and Testing i
MSIV Main Steam Isolation Valve ,
MWO Maintenance Work Order j
N00PS Nuclear Operations Department Policy Statement 1
N005 Nuclear Operations Department Standard '
NPRDS Nuclear Plant Reliability Data System i
NRC Nuclear Regulatory Commission l
NSE Nuclear Safety Engineering i
1
l
l
-- - _ _ - _
!
,
40
'
.
i
OER Operational Experience Review
(k)T On The Job Training
i O&M Operation and Maintenance
1 OMC Operations Maintenance Coordinator ,
'
OP Operating Procedure ,
OPA Operational Performance Assessment !
- PM Preventive Maintenance [
! PMT Post Maintenance Test :
,
POD Plan Of The Day L
a PORV Power Operated Relief Valve !
- PT Performance Test :
i
QA Quality Assurance .
l' QADIN Quality Assurance Department Instruction Nuclear F
QACPS Quality Assurance Organization Policy Statement
i QA05 Quality Assurance Organization Standard
! QC Quality Control
QCAR Quality Control Activity Report ;
<
QMT Quality Maintenance Team l
l QS Quench Spray
RCP Reactor Coolant Pump
i RS Recirculation Spray i
'
RWP Radiation Work Permit .
-
SALP Systematic Assessment of Licensee Performance t
i SG Steam Generator :
'
j SNSOC Station Nuclear Safety and Operating Committee
Significant Operating Experience Report
'
SOER l
Senior Reactor Operator
'
SS Shift Supervisor
j STA Shift Technical Advisor !
'
TS Technical Specification
i
TSC Technical Support Center '
i URI Unresolved Item l
-
WGDT Waste Gas Decay Tank
j WO Work Order
j WR Work Request l
l
- I
- :
i
)
1
i
!
!
-