ML20154R480
| 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: |
| References | |
| 50-298-86-01, 50-298-86-1, NUDOCS 8603310020 | |
| Download: ML20154R480 (10) | |
See also: IR 05000298/1986001
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APPENDIX
0.5. NUCLEAR REGULATORY COMMISSION
REGION IV
Report No.
50-298/86-01
Docket No.
50-298
License No.
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
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
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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
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).
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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.
(Closed) Violation (298/8204-01);
Failure to have administrative.
e.
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
valve squibs having two manufacturing dates marked on each squib.
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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
aid.
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(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.
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Coamunications
Licensee personnel interviews disclosed that communications within the
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maintenance organization, and with interfacing organizations was
very good, with the appropriate degree of formality.
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j.
Root Cause Analysis Determination
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Licensee personnel interviews disclosed that she licensee has no
documented program for determining root causes of maintenance-related
events.
Postmaintenance review of completed work requests does not
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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
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inspection of the maintenance progran in the mechanical area. One was
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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
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and qualifications.
a.
The licensee procedures and documentation associated with LER 85-017
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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
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" 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,
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NBI-LIS-1018"
(2)84-004 "RCIC Turbine Speed Controller"
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(3)84-010 " Main Steam Line Leak Detection"
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(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
all such relays in a periodicity of 10-12 years. Since such replace-
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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.
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6.
Review of Electrical Maintenance, Observation of Work, Work Activities, and
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Associated Quality Records
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The NRC inspector performed an in-depth inspection of the licensee's
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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.
EE-CB-1258 (CHG); Breaker for Tie to 250V Battery Charger Trip
c.
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.