ML20154R480

Insp Rept 50-298/86-01 on 860106-10.Potential Violations Noted:Failure to Have Adequate Procedures for Preventive Maint & Failure to Establish Training Program for Electrical & Mechanical Personnel

ML20154R480
Person / Time
Site:	Cooper
Issue date:	03/14/1986
From:	Boardman J, Ireland R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154R478	List: ML20154R480
References
50-298-86-01, 50-298-86-1, NUDOCS 8603310020
Download: ML20154R480 (10)

See also: IR 05000298/1986001

Text

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APPENDIX

0.5. NUCLEAR REGULATORY COMMISSION

REGION IV

Report No. 50-298/86-01

Docket No. 50-298 License No. DPR-46

Licensee: Nebraska Public Power District

P. O. Box 499

Columbus, Nebraska 68601

Facility Name: Cooper Nuclear Station

Brownville, Nebraska 68321

Inspection Conducted: January 6-10, 1986

Inspector- $h. o_bjdd 2/AV/74

John Boardman, Rea~ctor Inspector, Operations

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Pate '

Section, Reactor Safety Er~.nch-

Accompanied

by: Luther Jones, EG&G

Howard Stromberg, EG&G

Approved: [ m MM / J//<///4 '

R. E. Ireland, Acting ChieT,'Uperations D(te

Section, Reactor Safety Branch

Inspection Summary

Inspection on January 6 - 10, 1986 (Report No. 50-298/86-01)

Areas Inspected: _ Licensee maintenance activities, including maintenance program

implementation, maintenance program, instrumentation and control maintenance,.

electrical maintenance, and follow-up on previous inspection findings. The

inspection involved 124 inspector-hours onsite by one NRC inspector and two

consultants.

Results: Within the six areas inspected, two potential violations were

identified in two areas (failure to have procedures for preventive maintenance,

paragraph 2a, and failure to establish a suitable training program for electrical

and mecharical maintenance personnel, paragraph 3b).

8603310020 860314

PDR ADOCM 05000298

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DETAILS

1. Persons Contacted

• G. R. Horn, Nuclear Operations Division Manager

• J. Sayer, Acting Technical ' Staff M1 nager

• J. M. Meacham, Technical Manager

• D. L. Reeves, Training Manager

V. L. Wolstenholm. Quality Assurance Manager

• D. M. Norvell, Maintenance Manager

• E. M. Mace, Plant Engineering Supervisor

• W. E. Crawford, Maintenance Supervisor

D. A. Hopper, Mechanical Foreman

S. S. Freborg, Lead Mechanical Engineer

H. A. Jantzen, I&C Supervisor

G. A. Schmielau, I&C Foreman

M. E. Unruh, Maintenance Planner / Scheduler

L. P. Clark, Electrical Supervisor

S. J. Jobe, Electrical /I&C Engineer

L. F. Bednar, Senior Staff Engineer

• Denotes those attending the exit interview on January 10, 1986.

2. Licensee Actions on Previous Inspection Findings

a. (Closed) Violation (298/8411-01). Failure to have procedures for

maintenance of safety-related equipment.

The specific violation was the absence of a licensee procedure to

perform the manufacturer's minimum service lubrication recommendation,

for the Standby Liquid Control (SLC) System pump motor bearings, or

in lieu thereof, an engineering analysis and justification' for not

performing this lubrication.

The licensee established a lubrication periodicity for these bearings

which was compatible with the then existing manufacturer's recommecca-

tion. The licensee's generic response was that their existing

programs for vibration, bearing temperature, and oil analyses, in

conjunction with insulation megger readings, provided adequate

maintenance and detection programs for safety-related equipment.

The NRC inspector reviewed the specific maintenance actions for the

SLC pump motor bearings and found that the licensee had received a

revised technical manual from the manufacturer, dated 1984. This new

manual was for the two specific pumps at Cooper Nuclear Station (CNS). i

This manual recommended 19 preventive maintenance actions, having

periodicities ranging from 1 month to 5 years. A number of mainten-

ance actions, such as verification of fastener tightness, replacement

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of seals, and pump oisassembly and inspection were not covered by the

existing CNS maintenance concepts and procedures. Licensee personnel

stated that no review and analysis had been performed on this manual,

nor did existing procedures require such actions.

The NRC inspector also reviewed the licensee's vendor manual for the

CNS High Pressure Coolant Injection (HPCI) turbine and pump. A revi-

sion, dated January 1980, added 23 preventive maintenance actions with

periodicities ranging from I week to 5 years. Such actions included

cleaning, lubrication, and calibration of control and governor link-

ages; retorquing of bolting; and inspection of the actuator drive

mechanism for shaft bushing wear, gear wear, and gear backlash. These

actions were not included in the current CNS. maintenance program or

procedures. Again, licensee personnel stated that no review of this

vendor manual had been performed, nor was required by existing

procedures at CNS.

In both examples rt ziewed by the NRC inspector, the preventive

maintenance activi.ses recommended by the equipment manufacturer had

not been performed. Failure of the licensee to have procedures to:

(1) perform preventive maintenance recommended by the manufacturers of

safety-related equipment and systems, including the HPCI turbine pump

and the SLC pump motor bearings, or in lieu thereof, (2) perform an

engineering analysis with documentation of the basis for not

accomplishing recommended manufacturer's maintenance is'an apparent

violation of CNS Technical Specification 6.3.3 which requires that

procedures for preventive maintenance are to be provided.

(298/8601-01).

b. (Closed) Open Item 298-8411-03: Rewinding of Reactor Containment

Building Component Cooling Water (REC) System pump motors.

The NRC inspector had reviewed PMs performed on the REC pumps and

motors. All four motors had been rewound by an outside contractor who

subsequently had been disapproved by the licensee's QA department.

The licensee could not provide documentation of the acceptability and

compliance of this work. The licensee did not approve QA or design

criteria for the motor bearings, nor prohibit bearing substitution.

These four motors were scheduled for replacement as part of the

licensee's Equipment Qualification (EQ) program, and have subsequently

been replaced. Licensee personnel told the inspector that no other

safety-related motors presently installed had been reworked by

unapproved vendors.

c. (Closed) Open Item 298-8106-03: Vendor Qualification. The two

specific vendors discussed (MIDC0 and Nebraska Testing Laboratories)

were subsequently audited by the licensee on June 11, 1981, and

April 21, 1981, respectively and found to be acceptable. Subsequent

changes in the licensee procurement quality program have answered

other concerns.

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d. (Closed) Violation (298/8226-01): Failure to have procedures to

identify changes in vendor, or component, acceptability not related to

vendor audits, or material deficiencies identified by the licensee.

Licensee Procedure QAI-16, Revision 10, Section 3.4, now contains

adequate controls for this concern.

e. (Closed) Violation (298/8204-01); Failure to have administrative.

controls for material having shelf life. The licensee now has

documented administrative controls for shelf life in Procedure 1.4,

Revision 4, approved December 19, 1985, " Requisitioning," and

Procedure 1.5, Revision 2, approved October 17, 1985, " Receiving."

f. (Closed) Open Item (298/8204-03): Standby Liquid Control (SLC) system

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valve squibs having two manufacturing dates marked on each squib.

The concern was which date was the valid basis for design life

detennination of this component required to initiate SLC injection.

The earlier date was that of the squib manufacture (according to

CONAX, the manufacturer). The latter date was that of the incorpora-

tion into an assembly by another manufacturer. The identified design

life was based on this latter date, so squibs having passed the design

life could not be installed based on the date-marking on the squibs.

g. (Closed) Open Item (298/8412-05): Mechanical Maintenance Training.

This item is included in unresolved hem 298/8601-02.

h. (Closed) Open Item (298/8412-05): I&C and Eiectrical Training. This

item is included in unresolved item 298/8601-02.

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3. Review of the Licensee Maintenance Program

The review of the licensee's maintenance program was expanded for this

inspection to provide a broad baseline of parameters which can affect main-

tenance. Significant findings are identified in the following paragraphs.

For this inspection, I&C was considered as part of the maintenance program;

through at-CNS I&C is part of the Operations organization.

a. Maintenance Procedures

(1) CNS was not strongly proceduralized in the area of maintenance.

Problems relating the lack of preventive maintenance procedures

are identified in paragraph 2.a.

(2) Other areas of maintenance management that did not appear to be

proceduralized, based on licensee responses to the NRC inspector,

include the following items:

(a) There was no documented system to provide management

information for determining the status of outstanding work

orders and maintenance planning.

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(b) There was no plant status monitoring system for monitoring

all maintenance department activities for normal operations.

Such a system was being generated for planned plant outages.

(c) There was no system to establish and periedically assess

indicators of maintenance performance.

(d) There was no procedure that described the criteria for

development of maintenance procedures.

(3) The licensee used contractors, corsultants, and vendors to

provide technical assistance as necessary in the preparation of

maintenance procedures. The INP0 " writers guide" was used as an

2 aid.

(4) The licensee had a documented program for equipment identification

and labeling (engraved, laminated) tags for both safety-related

and balance of plant equipment. Color coding was used; components

requiring equipment qualification (EQ) were color coded orange.

Safety system divisions.were color coded green or yellow.

b. Maintenance Training

,

NRC Inspection Report 50-298/84-12, paragraphs 6.d. and 6.e.,

identified inadequacies in the CNS training program for maintenance

mechanics in the mechanical, electrical, and instrumentation and

control disciplines. The latest CNS SALP Report 50-298/85-06, under

Functional Area "C", " Maintenance", identified this weakness and

recommended that the licensee establish and maintain a formal training

program for maintenance (electrical and mechanical) and I&C personnel.

The CNS Training Manager told the NRC inspector that no formal training

program had been initiated for electrical and mechanical maintenance

personnel. Also, the NRC inspector noted that the training billet for

the electrical maintenance instructor was vacant.

CNS Technical Specification 6.1.4 for plant staff qualifications

invokes ANSI N 18.1-1971 for minimum qualifications and training.

ANSI N 18.1-1971, Section 5.3, states that a suitable training program

'shall be established for technicians and repairmen to properly

prepare them for their assignments; and Section 5.3.4, states that

technicians and repairmen shall be trained by on-the-job training, or

by related technical training. The CNS training manager, in response

to the NRC inspector, stated that he could not identify procedures or

documentation for electrical and mechanical maintenance personnel that

fulfilled the requirements of ANSI N 18.1-1971, Section 5.3. The

failure to establish a suitable training prngram for electrical and

mechanical maintenance personnel is a potential violation of CNS

Technical Specification 6.1.4 which requires qualification and

training to meet the requirements of ANSI N18.1-1971. (298/8601-02).

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c. Facilities and Material

(1) Maintenance supervision did not consider that maintenance

activities were negatively affected by facilities, tools, instru-

ments, equipment, or the availability of replacement parts or

components, except for hoisting and rigging gear in the turbine

area during outages.

(2) Warehouse supervision considered storage space adequate at

present, except possibly during peak periods a*.sociated with

major outages.

(3) The licensee's inventory control s,". tem provided tne status of

material availability, identified reorder points, and showed

material location.

(4) Access to storage areas was controlled. The average time to

obtain material from the warehouse was identified by warehouse

supervision as approximately 5 minutes.

d. Predictive Maintenance

The licensee used tath vibration and oil analyses for predictive

maintenance for safety-related equipment.

e. Nuclear Plant Reliability Data System (NPRDS)

Licensee personnel indicated that they made about 35 inquiries a

year to NPRDS. CNS inputs to NPRDS were indicated as being

3-to-5 months behind. CNS had established a commitment to INP0 to be

current by March 1, 1986. Licensee personnel did not indicate

program changes were being considered to assure that NPRDS would

remain current and NPRDS was not considered particularly " user

friendly."

f. QC Coverage of Maintenance Activities

QC coverage was by "QC checkpoints." The NRC inspector found that

QC coverage for electrical preventive maintenance procedures was

" essentially none," for mechanical preventive maintenance procedures,

about 25%, and for I&C preventive maintenance procedures, about 15%.

Most critical instrumentation was covered by surveillances procedures,

which had an estimated 60% QC coverage.

g. Plant Cleanliness Control

Licensee personnel interviews disclosed that there was a program for

assigning general plant house-cleaning, but that standards of

cleanliness had not been specifically assigned for various plant

locations. Work order forms did not include a specific check-off for

cleanliness control.

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h. Maintainability

Licensee personnel interviews disclosed that equipment maintainability

was not considered in the original design and that no documented

maintainability improvenent program was presently implemented.

i. Coamunications

Licensee personnel interviews disclosed that communications within the  !

maintenance organization, and with interfacing organizations was

very good, with the appropriate degree of formality.

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j. Root Cause Analysis Determination l

Licensee personnel interviews disclosed that she licensee has no

documented program for determining root causes of maintenance-related

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events. Postmaintenance review of completed work requests does not

include a review and determination as to whether or not a problem

should be entered in the corrective action system.

4. Implementation Review of Licensee Maintenance Program

The NRC Inspector selected two recent LERs and performed an in depth

l inspection of the maintenance progran in the mechanical area. One was

l LER 85-017, "High. Pressure Injection System Inoperability"; the other was

LER 85-018, " Group 3 Isolation." Maintenance history, work item tracking

forms, and Maintenance Work Requests (MWRs) were reviewed. Licensee

personnel were interviewed to determine their functional responsibilities

l and qualifications.

a. The licensee procedures and documentation associated with LER 85-017

I were reviewed. No violations cr deviations were identified.

b. The licensee procedures and documentation associated with LER 85-018

as well as the MWR (WI 85-4229) for repair of the pump after remo'.al

from service were reviewed as follows:

(1) In the MWR for the pump removal and replacement (WI-85-4229), the

! " Test Equipment Used" line was not filled out. Though this did

not comply with CNS Procedure 7.0.1, paragraph V.D.1.0, which

stated that "All test equipment and calibrated tools utilized to

perform the work or testing shall be listed by their identifica-

tion numbers in the Test Equipment Used Block," this appeared to

be an isolated case. The test equipment was in calibration and

the licenste corrected this documentation omission. The

inspector has no further questions regarding this isolated event

at this time.

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(1)84-001 " Reactor Vessel Water Level Indicating Switch, l

NBI-LIS-1018"

(2)84-004 "RCIC Turbine Speed Controller" ,

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(3)84-010 " Main Steam Line Leak Detection" l

(4)84-011 "HPCI Overspeed Trip"

No violations or deviations were identified during the review.

b. A completed maintenance package (WI 84-1841) for the repair of a relay

(PCIS-REL-K14) in the Main Steam Isolation Valve (MSIV) Group 1 isola-

tion control circuitry was reviewed. It was noted that Non-Conformance

Report (NCR) 2963 had been generated. When this NCR was requested for

review it could not be located. It was identified as having been put

on a QA hold. The NRC inspector subsequently was provided with the

NCR. It dealt with the conservative failure of GE type CR 120 A relays.

All such relays installed at CNS, according to licensee personnel, were

installed in fail-safe applications. Correctiv_e action was completed

except for the generation of a preventive maintenance task to replace

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all such relays in a periodicity of 10-12 years. Since such replace-

ment does not have identified safety significance and was a single

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example, the inspector has no further questions of this item at this

time.

Work activities involved in the performance of surveillance procedures

were reviewed to determine if licensee personnel were following the

appropriate maintenance procedures. (Functional testing of the RCIC

Steam Line High Flow Instrument, and RHR Loops A and B Drywell

Pressure Containment Spray Calibration.)

No violations or deviations were identified during the review.

( 6. Review of Electrical Maintenance, Observation of Work, Work Activities, and

l Associated Quality Records

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( The NRC inspector performed an in-depth inspection of the licensee's

i electrical maintenance program.

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The following licensee document types were reviewed:

a. Maintenance history.

b. Work item tracking forms.

c. Maintenance work requests.

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d. Qualification records.

e. Document control procedures.

f. Rylacement part control records.

Licensee electrical maintenance personnel were interviewed to determine

their areas of responsibility, functions and qualifications.

The NRC inspector reviewed procedures and other documentation associated

with the following completed maintenance activities:

a. HPCI-MOT-ALOP; HPCI Auxiliary Oil Pump Repair.

b. EE-CB-125B (CHG); 125V Charger Output Breaker Trip Investigation.

c. EE-CB-1258 (CHG); Breaker for Tie to 250V Battery Charger Trip

Investigation.

d. No. 2 DG Exciter Panel Breaker No. 7 Fuse Troubleshooting.

e. Replacement, Valve Operator Connection Modification.

It was noted during the inspection of the documents for these completed

items, that during the valve operator connection modification work

(VI-85-2340), valve RCIC-MOT-M016 was modified, inspected, ar.d tested.

However, at a later date, this valve did not function. The investigation

found that the valve had been incorrectly connected. Subsequently an

explanatica for this item was provided. The initial test was a preliminary

test with no system pressure. The motor was operating incorrectly as a

series motor. The subsequent surveillance tests (6.3.1.4 and 6.3.2.6) to

prove operability were the tests that showed the motor improperly wired

and inoperable.

Work activities in the performance of a surveillance procedure (Station,

Diesel Fire Pump, CAS, and PMIS Battery Weekly Check) were witnessed to

verify that the electricians performing the job followed the appropriate

licensee procedure.

No violations or deviations were identified.

7. Exit Interview

The NRC inspectors met with licensee representatives (denoted in

paragraph 1) and the Senior Resident Inspector on Jan'ary 10, 1986, and

summarized the scope and findings of inspection activicies.