ML20155D527
| ML20155D527 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/20/1988 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 8806150233 | |
| Download: ML20155D527 (3) | |
See also: IR 05000440/1987025
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MAY 2 01988
Docket No. 50-440
The Cleveland Electric Illuminating
Company
ATTN: Mr. Alvin Kaplan
Vice President
Nuclear Group
10 Center Road
Perry, OH 44081
Gentlemen:
Thank you for your letter of April 29, 1988, in response to our Inspection
Report No. 50-440/87025 for the Perry Nuclear Power Plant. After our review
of your response, and the telephone conversations between Mr. 5. Reynolds of
our staff and Mr. C. Jones of your staff on May 6,1988, it was agreed that
certain actions need to be addressed in a followup written response. These
actions are identified below along with coments to emphasize the importance
placed on the problems identified during the inspection.
A.
Violation 440/87025-038. Our concerns include:
1) nine motor operated
valves (MOVs) had inadequate lubrication; 2) repetitive tasks for those
M0Vs were last completed in 1985; and 3) those repetitive tasks had been
rescheduled well past the "late" due date.
Procedure PAP 0906 does not
provide criteria for making decisions to defer maintenance nor does the
procedure require that documented technical evaluations be made before
deferring maintenance. Discussions with responsible system engineers
indicated that effects on plant safety, operability, or reliability were
not considered before rescheduling M0V related maintenance.
As agreed with Mr. C. Jones, your supplemental response will
91ude the
actions taken to resolve our concerns about the nine MOVs
including the
effects, if any, on plant safety, operability, and reliability.
B.
Violation 440/87025-03C. Our concern is that the M0V manufacturer specified
the upper bearing be lubricated but procedure PMI-0030 did not include such
an instruction which resulted in several M0Vs not being lubricated.
As agreed with Mr. C. Jones, your supplemental response will include the
actions taken for all applicable MOVs, and to the effetts, if any, on plant
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safety, operability and reliability.
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C.
Violation 440/87025-03A. Our concern is that completed work orders do no't
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include accurate information for maintenance history data and trending.
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8806150233 880520
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The Cleveland Electric
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MAY 201988
Illuminating Company
As agreed with Mr. C. Jones, your supplemental response will include the
actions taken to ensure'that accurate maintenance history data is recorded,
readily available, and utilized to provide effective trending.
D.
Violation 440/87025-03D. Our concern is that problems identified during
. Audit PIO 87-12 bypassed the established corrective action process because
the problems were incorrectly identified as "observations" rather than
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"deficiencies" which would be corrected thru Action Requests. The example
in our inspection report of untimely corrective action was an obvious,
non-subjective, violation of your QA Program and 10 CFR 50, Appendix B,
Criterion XVI and clearly should have been a "deficiency".
Even though only one example of our concern was documented in our report,
as discussed with members of your staff, there were several other observations
that should have been "deficiencies".
An objective of your audit system should be to assess the effectiveness of
the processes controlled by your QA Program.
"Performance related" means
actions that affect or have the potential to affect performance of structures,
components , or systems.
Overall, your response did not address the salient points that impact plant
system performance; instead, you emphasized corrective actions that partained
to correction of instructions and documentation.
Your supplemental response is expected within 30 days of the da2e of this letter.
Thank you for your cooperation.
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Sincerely,
.
, DRIGINAl. SIGNED BY. HUBERT J. MILLER
Hubert J. Miller, Director
Division of Reactor Safety
Enclosure: Ltr dtd 4/29/88
See Attached Distribution
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The Cleveland Electric
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Illuminating Company
gjAY 2 01988
Distribution
cc:
F. R. Stead, Director, Perry
Plant Technical Department
M. D. Lyster, General Manager,
Perry Plant Operations Department
Ms. E. M. Buzzelli, Manager,
Licensing and Compliance Section
cc w/itr dtd 04/29/88:
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Terry J. Lodge, Esq.
James W. Harris, State of Ohio
Robert M. Quillin, Ohio
Department of Health
State of Ohio, Public
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Utilities Conmission
Murray R. Edelman
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P.O.
BOX 97
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PEARY, OHIO 44081
o TELEPHONE {216) 259-3737
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ADORESS to CENTER ROAD
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Serving The Best location in the Nation
PERRY NUCLEAR POWER PLANT
Al Kaplan
t' ICE PRESJOENT
m ow,
April 29, 1983
PY-CEI/NRR-0345 L
U.S. Nuclear Regulatory Commission
Docume nt Control Desk
Washington, D. C.
20555
Perry Nuclear Power Plant
Docket No. 50-440
Response to Notice of
Violation 50-440/37025-03
Dear Gentlemen:
This letter acknowledges receipt of the Notice of Violation contained within
Inspection Report 50-440/87025 dated March 31, 1988.
The re po rt identified
areas examined by Mr. W. Kropp and others during their inspec tion conducted
f rom January 11, 1938 through February 9,1988 of activities at the Perry
Nuclear Power Plant , Uni t 1.
Our response to Notice of Violation 50-440/87025-03 is attached. Please call
should you have any additional questions.
Very truly yours,
1M4
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Al Kaplan
Vice President
Nuclear Group
AK: cab
At tac hme nt
cc:
T. Colburn
K. Connaughton
H. Miller - USNRC, Region III
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'J/n
MAY 2
1983
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Attachment
PY-CEI/NRR-0845 L
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Page 1 of 9
50-440/87025-03
Restatement of Violation
10 CFR 50, Appendix B, Criterion V, as implemented by PNPP, Operational Quality
Assurance Plan, Section 5.0, requires that activities affecting quality be
prescribed by instructions or procedures and accomplished in accordance vi:h
those instructions or procedures.
Section 5.0 further requires procedures to
include appropriate quantitative or qualitative acceptance criteria for
determining that important activities have been satisfactorily accomplished.
Contrary to the above:
Procedure PAP-0906, "Control of Haintenance Section Preventive
a.
Maintenance," Revision 1, did not include criteria to make technical
evaluations for rescheduling preventive maintenance activities. As a
result, repetitive tasks (preventive maintenance) already several months
past due, vere rescheduled for nine motor-operated valves in the residual
heat removal and liquid radvaste systems without evaluations of the
effects the delays could have on plant safety, operability, or
reliability. (440/87025-03B)
3.
The licensee failed to fully accomplish Preventive Maintenance
Instruction, PMI-0030, "Maintenance of Limitorque Valve Operat)rs,"
Revision 1, as follovs:
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The inspector observed that valve stems for several residual heat
removal system and liquid radvaste system valves vere lubricated with
Neolube although PMI-0030 specified Nebula EPO.
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There vas no objective evidence that two residual heat removal system
valves had been electrically and manually cycled as specified in the
post maintencnce requirements of PMI-0030.
(440/87025-03C)
C.
The licensee failed to properly implement Administrative Procedure
PAP-0905, "Vork Order Process," Revision 7, which outlined the
requirements for processing vork orders (V0) from initiation to closure as
follows:
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V0 87-9677 - Summary description did not accurately reflect the
activity perforced;
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VO 87-5727, 87-10390, 88-0080 - Incomplete or incorrect corrective
action indicated on VO Closing and Summary Sheet;
V0 87-6175, 87-7385, 87-8746, 87-9361, 87-9498, 87-9677, 87-10213 -
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Incorrect or inadequate immediate failure cause identified on the Vo
Closing and Summary Sheet;
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Page 2 of 9
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VO 87-2249, 87-8746, 87-9361, 87-9677, 87-10390 - Incorrect or
incomplete VO closing codes;
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V0 87-4825, 87-8298, 87-8597, 87-9677 - Incorrect or incomplete Master
Part List (MPL) numbers; and
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V0 87-9361 - Inadequate closing summary on the VO Closing and Summary
Sheet.
(440/87025-03A)
D.
The licensee failed to fully accomplish Nuclear Quality Assurance
Department procedure, NOAD 1840, Revision 2, "Audit Performance," Section
6.2, which required that deficiencies noted during audits be documented on
Action Pequests.
Deficiencies identified during Audit 87-12,
"Effectiveness of Corrective Action" vere listed as observations;
therefore, the established corrective system was bypassed. One
observation pertained to continued untimely and ineffective corrective
action, which prior to Audit 87-12, had also been identified as a concern
by the licensee's OA organization and the NRC.
(440/87025-03D)
This is a Severity Level IV violation (Supplement I).
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Correct ve Action Taken and Results Achieved
A.
Failure to document technical evaluations for rescheduling preventive
mair.tenance activities.
CEI egrees that PAP-0906 did not specifically include criteria to make the
technical evaluations nor require documentation of the evaluations.
However, system engineers involved in rescheduling repetitive tasks have
used engineering judgment, verbal instructions from unit leads, and/or
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informal desk-guide type instructions when performing this activity. The
issue is net whether technical evaluations vere performed for rescheduled
repetitive tasks, but whether this evaluation was documented.
In order to
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allov for documentation of the technical evaluation, a Preventive
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Maintenance Deferral Evaluation / Justification Sheet has been developed and
is beiag incorporated into the appropriate repetitive task procedures.
This form provides for a documented "Justification for Reschedule" and
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"Effect on Component / Consequences of Non-performance" for safety-related
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repetitive tasks. Also, informal desk-guide instructions are being
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developed which vill provide the system engineer with a list of
appropriate questions to ask when considering approval or denial for
rescheduling of a task. The form and the desk-guida instructions vill
provide consistent documented technical justification of approval or
denial for rescheduling of safety-related repetitive tasks.
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Attcchment
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PY-CEI/NRR-0845 L
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Page 3 of 9
B.
Several examples vere identified of failure to fully accomplish Preventive
Maintenance in accordance with PMI-0030.
1.
The inspectors observed inconsistencies in valve stem lubrication.
CEI agrees that inconsistencies existed among the as-found conditions
as well as the procedures and instructions which control the
lubrication of these valve stems. As a result of these
inconsistencies, procedures have been revised and training has been
performed for maintenance personnel invclved in this activity. These
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inconsistencies vere also evaluated as described below. An
engineering evaluation was performed to determine the significance of
valve stems lubricated with Neolube instead of Nebula EPO. The
conclusion was that all of the valve stems identified vere adequately
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lubricated in accordance with vendor recommendations. Hovever,
improvements in lubrication practices should be made. The vendor of
these valves recommends Neolube as an acceptable valve stem lubricant.
Neolube is a graphite type lubricant that dries upon application to
the stem, leaving a fine dry graphite film coating.
In cases where
only Neolube exists on the valve stems, it should be recognized that
PMI-0030 did not require stem lubrication if the existing lubrication
was determined to be sufficient. Additionally, for MOVATS testing of
these valves per General Engineering Instruction (GEI)-0056, Neolube
vas utilized as the valve stem lubricant.
In cases where both Neolube
and Nebula EPO exist on the valve stem, it is possible that
lubrication with Nebula EP0 vas deemed necessary during a performance
of PMI-0030. This PHI did not require cleaning of the stem before
applying lubrication, thus potentially resulting in both Neolube and
Nebula EPO being present. An engineering evaluation of the
compatibility of the two lubricants determined that mixing of the two
lubricants vill have no deleterious effect on the valve or its
operability.
For the case where PMI-0030 did not require lubrication
of the MOV upper bearing, a review of the vendor recommendations
determined that the upper bearing should be lubricated periodically,
resulting in a change to PMI-0030 on January 29, 1988.
The following procedure changes and training have been completed.
PHI-0030 as revised January 29, 1988 and GEI-0056 vas revised January
28, 1988 to be consistent in future lubrication activities.
For
future Rockvell Hermaseal valve stem lubrication, Nebula EP0 vill be
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used.
For future stem lubrication of rising stem gate and globe
valves, Never-Seez vill be used. Never-Seez is a lubricant that
leaves a vet film coating which does not dry upon application.
Mobilgrease 28 vill be used in limit switch gear boxes, and Nebula EP0
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vill be used on operator main nousings and upper bearing grease
fittings. Also, the instructions nov require that when a valve stem
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needs to be relubricated, it shall first be thoroughly cleaned and
inspected prior to relubrication. Appropriate maintenance workers
have been trained to these changes.
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Page 4 of'9
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2.
The inspectors found no objective evidence of valve cycling af ter
performance of PMI-0030. Research into the work history of the
subject RHR valves determined that the valves have been cycled since
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the performance of the PMI. This was performed on January 9, 1988 in
accordance with the periodic Technical Specification surveillance to
verify operability .and no problems were experienced. PMI-0030 has
been revised (effective April 29, 1988). to specify that the Control
Room Unit Supervisor shall establish retest requirements. . A further,
revision to PMI-0030 vill provide for documentation of retest
completion.
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C.
Several examples were identified of inadequate and/or incomplete
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documentation during the review of completed V0s.
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1.
VO 87-9677: Summary. description did not accurately reflect the
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activity performed.
This VO vas performed to troubleshoot and repair a Residual Heat
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Removal (RRR) pump not initiating on high heat exchanger level as
expected. The cause of this problem was determined to be a level
transmitter lE12-N008A being out of calibration. The corrective
actions taken with the V0 vere recalibration of the trensmitter and a
circuit loop check. The closing summary as stated on the VO Closing
and Summary Sheet vas, "Recalibrated transmitter and loop checked
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Sat."
PAP-0905 in section 6.7, Vork Order Package Closeout, requires
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the planner or vork supervisor to ". . .vrite a short, concise summary
statement of the work actually performed..." Ve believe the
requirement of PAP-0905 was met end the summary description did
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accurately reflect the activity performed. The only enhancement that
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could be made to the summary would be to include the transmitter MPL
number. However, this MPL number was adequately reflected on the same
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Closing and Summary Sheet within the corrective action summary
description.
2.
VO 87-5727, 87-10390, 88-0080:
Incomplete or incorrect corrective
action indicated on VO Closing and Summary Sheet.
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a.
VO 87-5727 is still in the planning stages; no vork has been
performed on this V0; and thus, no Closing and Summary Sheet has
been nor should have been complete for this V0.
Ve believe that
the V0 number should have been 87-5722 in your inspection report.
The VO Closing and Summary Sheet for this VO initially stated in
the corrective action summary, "All vork completed per the job
traveler; change out and H0 VATS per UR PPDS-2554". This was
deemed insufficient and was revised to "Replaced Limitorque
operator with rebuilt spare, performed MOVATS on actuator per
GEI-0056, adjusted torque switch per SCR 1-87-1576, and installed
nev limiter plate". This change has been incorporated into the
PPMIS history file for this V0.
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PY-CEI/NRR-0845 L
Page 5 of 9
b.
V0 87-10390 vas performed to troubleshoot intermittent relay
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problems in the Feedvater Control circuitry and to change three
relays as directed by Design Change Package (DCP)87-807. The V0
Closing and Summary Sheet initially stated in the corrective
action summary, "Implemented DCP 87-0807".
This was deemed
insufficient and was revised to, "Replaced existing time delay
relays with Potter-Brumfield relays per DCP 87-807.
Calibrated
relays and obtained voltage readings for operating point of PDU
output switch.
Cleaned contacts and calibrated associated relays
in control panel".
This change has been incorporated into the
PPMIS history file for this V0.
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c.
VO 88-0080 vas performed to replace the charge for the Standby
Liquid Control squib valve per Surveillance Instruction
(SVI)-C41-T2002.
During the performance of this VO power
indication problems vere observed.
Troubleshooting of the
circuitry identified two blown fuses which vere promptly replaced.
The V0 Closing and Summary Sheet corrective action summary
initially only described the squib valve charge replacement. This
was deemed insufficient and was revised to include the circuitry
troubleshooting and replacement of identified blown fuses. This
change has been incorporated into the PPMIS history file for this
V0.
3.
VO 87-6175, 87-7385, 87-8746, 87-9361, 87-9498, 87-9677, 87-10213:
Incorrect or inadequate immediate failure cause identified on the VO
Closing and Summary Sheet.
a.
V0 87-6175 vas performed to modify the stem and manufacture a new
stem nut for valve lE12-F0024A in accordance with DCP 87 463.
The
VO Closing and Summary Sheet initially stated in the immediate
failure cause summary, "Modification of valve stem".
This was
deemed incorrect and was revised to "N/A" since the V0 vas only
implementing a design change. This change has been incorporated
into the PPMIS history file for this V0.
b.
VO 87-7385 facilitated the mechanical portion of vork required to
implement DCP 87-162A, which replaced the lE22-C0004A diesel
engine with an electric motor. The VO Closing and Summary Sheet
initially stated in the immediate failure cause summary, "Replace
diesel engine (Petter diesel) due to diesel failure". This was
deemed incorrect and was revised to "N/A" since the VO vas only
implementing a design change. This change has been incorporated
into the PPMIS history file for this V0.
c.
VO 87-8746 was performed to troubleshoot and repair the Division
II Diesel Generator due to the field not flashing.
The V0 Closing
and Summary Sheet initially stated in the immediate failure cause
summary, "Diesel vould not field flash". This was deemed
incorrect and was revised to "Unable to identify /unknovn" since
the troubleshooting failed to identify any problems. This change
has been incorporated into the PPMIS history file for this V0.
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Page 6 of 9
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d.
VO 87-9361 was performed to troubleshoot and repair a leak from a
snubber located above an RHR pressure transmitter lE12-N0050B.
The VO Closing and Summary Sheet initially stated in the immediate
failure cause summary, "steam leak at snubber". This was deemed
insufficient and was revised to "Instrumentation tubing connection
leaking. Loose connection" since the problem was identified as a
loose tubing connection. This change has been incorporated into
the PPMIS history file for this V0.
e.
VO 87-9498 vas performed to troubleshoot a Division II Diesel
Generator failure to start during the performance of
SVI-R43-T1318. The VO Closing and Summary sheet initially stated
in the immediate failure cause summary, "Diesel Div. II did not
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see pneumatic start".
This was deemed insufficient and vas
revised to "Not identified - Suspect solenoid start valves
1R43-F0037B and F0030B" since the troubleshooting failed to
pinpoint the cause. This change has been incorporated into the
PPMIS history file for this V0.
f.
VO 87-9677 vas performed to troubleshoot and repair incorrect
level indication for a RHR heat exchanger. The VO Closing and
Summary Sheet initially stated in the immediate failure cause
summary, "RHR HX A level indication is low".
This was deemed
insufficient and was revised to "Level transmitter lE12-N0008A out
of calibration" since the calibration problem is the cause which
vould be utilized in Failure Analysis trending. This change has
been incorporated into the PPMIS history file for this V0.
g.
VO 87-10213 was performed to repair bad connectors for two LPRMs
reading downscale. The VO Closing and Summary Sheet states in the
immediate failure cause summary, "Bad connectors". This was
deemed adequate since the problem was downscale LPRMs and the
immediate cause was bad connectors.
Identification of the cause
of bad connectors vould be part of the root cause evaluation as
part of the Failure Analysis program and is thus outside the scope
or requirements of PAP-0905.
4.
VO 87-2249, 87-8746, 87-9361, 87-9677, 87-10390:
Incorrect or
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incomplete VO closing codes.
The ineffectiveness of VO closing codes was identified by CEI during
the INP0 Maintenance Self Assessment which was completed in November
of 1987. These codes were initially designed to aid in failure
analysis. However, due to recommendations provided f rom the Failure
Analysis committee and the ongoing development of the Reliability
Information Tracking System (RITS), the decision was made to eliminate
many of these PPMIS closing codes from the PAP-0905 vork order
process. The failure analysis program needs will be better supplied
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through a centralized evaluation of the existing V0 closing summaries.
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Page 7 of 9
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5.
VO 87-4825, 87-8298, 87-8597, 87-9677:
Incorrect or incomplete Master
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Part List (MPL) numbers.
The concern over MPL numbers chosen during V0 initiation was
identified by CEI during a QA audit report PIO 87-12. "Effectiveness
of Corrective Action", issued July 29, 1987. PAP-0905 states that Vos
should, when practical, address only one MPL number, and that single
MPL numbers need not be addressed on V0s written to fill and vent
instrumentation, for troubleshooting, or on standing V0s.
a.
VO 87-4825 was written to determine the cause of a Reuter-Stokes
indexer failure. The MPL number utilized to open this VO vas
"N/A" since the indexer was not installed in the plant and thus
had no MPL number. This indexer was removed from the field and
replaced with a new indexer on March 26, 1987 in accordance with
VO 87-2620. The MPL number used for VO 87-2620 was 1C51-J0002C
and the failure cause was identified as "unknovn, VO 87-4825
vritten to troubleshoot failed indexer". VO 87-4825 could not
have had a MPL number assigned to a salvaged component no longer
installed in the field. However, to ensure identification of this
VO during future trending or failure analysis, the work summary
specified the MPL number of the component when it was installed in
the field and also referenced VO 87-2620 as the VO vhich
originally removed the component from the field. Therefore, ve
believe that this VO vas written properly and is not an example of
a violation.
b.
VO 87-8298 vas vritten to troubleshoot a contact failure to open
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on relay 1E12-K42. The MPL number utilized to open this VO vas
the system HPL 1E12. The Plant Equipment Master-file System
(PEMS) which ties into PPHIS to provide equipment data based on
the HPL number input, does not contain MPL numbers for relays.
Therefore, the identification number for this relay could not have
been used as the VO initiating MPL number. However, to ensure
identification of this VO during future trending or failure
analysis, the work summary specified the problem as a relay
1E12-K42 failure to open.
Therefore, ve believe that this VO vas
written properly and is not an example of a violation,
c.
V0 87-8597 vas written to troubleshoot a lov temperature
indication for the Division I Diesel Generator lube oil.
Since
the problem had not yet been identified, the MPL number utilized
to open this VO vas the DG lube oil system HPL 1R47.
If a
specific component vere to be identified as the problem, the only
way to change the MPL number vould be to void the VO and then open
a nov VO vith that HPL number. Nonetheless, troubleshooting
failed to identify any problems.
For future trending or failure
analysis the suspected trouble components are vell documented
throughout this V0.
Therefore, ve believe that this VO vas
written properly and is not an example of a violation.
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d.
V0 87-9677 was written to troubleshoot and repair incorrect level
indication for a RBR heat exchanger.
Since the problem was
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suspected to be the controller 1E12-R0604A, this HPL number was
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utilized to open this V0.
Troubleshooting identified the level
transmitter 1E12-N0008A as being out of calibration. Again, the
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only way to change a VO initiation HPL number is to void the V0
and then open a new VO vith the nev MPL number.
Since this is not
required and extremely inefficient, this vill not be done.
However, to ensure identification of the VO during future trending
or failure analysis, the corrective action identified in the
Closing and Summary Sheet specifies the required recalibration of
level transmitter 1E12-N0008A. Therefore, ve believe that this VO
vas written properly and is not an example of a violation..
6.
VO 87-9361:
Inadequate closing summary on she VO Closing and Summary
Sheet.
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This VO vas performed to troubleshoot and repair a leak from a snubber
located above an RHR pressure transmitter lE12-N00508. The VO Closing
and Summary Sheet initially stated in the closing summary, "No leakage
anymore". This was deemed insufi4cient and was revised to "Revorked
tubing fitting with reactor seal #5" since this was the actual work
required to correct the problem. This change has been incorporated
into the PPMIS history file for this V0.
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D.
The concerns identified in Audit PIO 87-12 vere listed as observations
because they were subjective and related to ef fectiveness of
implementation of the corrective action programs as opposed to compliance
with the procedurer. The Quality Assurance procedure, NOADI-1840,
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requires that each deficiency be documented on an Action Request (AR).
As indicated in your report, our audit program has become more
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"performance related". The audit found compliance with the program to be
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adequate but the deficiency noted was "performance related". The line
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which separates deficiencies from improved performance is not vell defined
and is open to interpretation resulting in this deficiency being
documented as a recommendation rather than an AR.
As for your identified
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example, the audit organization has re-evaluated the effectiveness of the
Condition Report program and noted an improvement in both number open and
mean time for closure of Condition Reports. This improvement was
partially due to actions taken as a result of the recommendraions in Audit
PIO 87-12.
Corrective Action To Avoid Further Violations
A.
The Preventive Maintenance Deferral Evaluation / Justification Sheet as
discussed previously vill be formally incorporated into IAP-0501 and
PAP-0906, for Instrumentation and Control Section and Maintenance Section
respectively, by June 30, 1988. The guidelines for performing a proper
technical evaluation for rescheduling repetitive tasks vill be provided to
the appropriate engineers by May 30, 1988.
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B.
1.
As discussed previously, procedure changes relative to the valve
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lubrications were completed January 29, 1988. Training for
appropriate maintenance personnel to these procedure changes has also
been completed.
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2.
The previously discussed revision to PMI-0030 to provide for
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documentation of retest completion vill be complete by May 20, 1988.
C.
To ensure that the intent of the requirements of PAP-0905 is adequately
met, the following corrective actions have been or vill be implemented.
1.
Training is being provided to work supervisors and planners
emphasizing their VO reviev responsibilities and the importance of
providing adequate summaries on the VO Closing and Summary Sheet.
This effort vill be complete by May 31, 1988.
2.
A Reliability Information Tracking System (RITS) is being implemented
manually and vill be fully computerized by April 30, 1989. The
objective of this program is to analyze component failures, and based
on the results, recommend corrective actions to prevent recurrence.
As a result of this program, changes are being made to PAP-0905, Vork
Order Process.
a.
A Program Change Request (PCR) has been initiated to provide a
section on the VO Closing and Summary Sheet for MPL numbers of all
affected equipment. This vill ensure a greater capture percentage
when trending for failure analysis or planning a VO on a
particular component. This PCR vill be complete by
November 30, 1988.
b.
PAP-0905 vas revised (effective March 1, 1988) to eliminate the
need for the vork groups to determine "Failure Category" and
"Cause of Failure" closing codes. The RITS program vill utilize
the summaries within the VO package to consistently determine VO
closing codes for trending purposes when deemed necessary.
D.
To ensure that the interpretation between deficiency and improved
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performance is made conservatively, QA guidelines have been revised to
clarify the threshold for issuing ARs to include not only programmatic
deficiencies or noncompliance, but also significant deficiencies which
affect the effective implementation of processes. Appropriate QA
personnel vere . ained to this change April 29, 1988.
Date of Full Compliance
Full compliance vill be achieved upon full implementation of RITS by
April 30, 1989.
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