ML20196H295
| ML20196H295 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/02/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196H282 | List: |
| References | |
| 50-334-98-08, 50-334-98-8, 50-412-98-08, 50-412-98-8, NUDOCS 9812090039 | |
| Download: ML20196H295 (23) | |
See also: IR 05000334/1998008
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION I :
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l Report Nos. 50-334/98-08,50-412/98-08
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Docket Nos.
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50-334,50-412
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Licensee: Duquesne Light Company (DLC)
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Post Office Box 4 ;
! Shippingport, PA 15077 '
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Facility: Beaver Valley Power Station, Units 1 and 2
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inspection Period: October 26-30,1998
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Inspectors: J. Trapp, Team Leader !
! W. Cook, Project Engineer
! T. Eastick, Sr. Resident inspector
l M. Morgan, Sr. Resident inspector
l H. Nieh, Resident inspector -
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Approved by: P. Eselgroth, Chief
Reactor Projects Branch 7
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9812090039 981202
PDR ADOCK 05000334
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EXECUTIVE SUMMARY
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Beaver Valley Power Station, Units 1 & 2
NRC inspection Report 50-334/98-08 & 50-412/98-08
! Beaver Valley Units 1 & 2 remained at rated power throughout the duration of this
3 inspection. The team directly observed approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of operator and
maintenance activities. The Nuclear Regulatory Commission (NRC) Inspection Procedure
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93802, Operational Safety Team inspection (OSTI) was considered in the scope of review
for each section of this report.
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Operations
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- Operator actions observed during this inspection were all conducted in a safe and
corttrolled manner in accordance with plant procedures. Operations personnel
consistently adhered to management standards and expectations regarding
l communications, and control board awareness. Three-part communications, peer
, and self-checking were routinely used by the operators. The team observed several i
. shift turnovers and concluded that turnovers were effective in ensuring that the
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operators were wellinformed of plant conditions, and that important plant status
information was conveyed to the oncoming shift. Non-licensed operators did an
- excellent job taking plant logs and addressing plant deficiencies during the shiftly
rounds. Log keeping practices were consistent with the administrative
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- * The safety tagging requirements established for maintenance activities were
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appropriate. The recent change to a computer based clearance tagging process was
noted as an enhancement. The implementation of the safety and configuration
! tagging administrative requirements by plant operators was effective.
- The present process' for monitoring the status of equipment / components was
appropriate. Operations shift personnel employed rigorous controls on entering a
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j Technical Specification Limiting Condition for Operation. The control room staff was ,
wellinformed of ongoing activities in the plant. The shift management provided l
appropriate oversight of shift activities and pre-evolution briefs were well organized.
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Additionally, the team concluded that the Bases for Continued Operation for Unit 2
were completed in a manner consistent with NRC guidance. j
- The key control practices observed were acceptable. The minor administrative
4 discrepancies noted by the team were addressed by the operations staff. i
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e The team concluded that overall procedure adherence / usage was excellent. The
quality of the procedures reviewed was adequate. Operators were aware of
j management's expectations for procedure compliance. A large backlog of
recommended procedure revisions exists. The large backlog of recommended l
procedure revisions indicated the need for a more focused effort to incorporate l
these changes to enhance the overall quality of operation's procedures.
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- A review of 1998 cycle requalification training records indicated that licensed
operators for both units were up-to-date with their required annual requalification
training and were completing their requalification training in a timely manner.
The licensee has appropriate requirements established for operators working in the
" controls area" of the main control room. The team noted that these standards
were met during control room observations. The team found that the NSS and
ANSS, as well as operation's management, provided appropriate oversight of shift
activities. Management's standards and expectations have been clearly established
in procedures, during routine crew lunchtime meetings with the General Manager of
Nuclear Operations, and during the bi-weekly meetings with shift supervision.
- The team concluded that while the self assessment program satisfied administrative
requirements, the operation's self assessments reviewed did not consistently
provide management with worthwhile operator performance insights or recommend
improvements.
Maintenange
- The efforts to reduce the fairly sizeable corrective maintenance backlog have not ,
been fully effective. Station management established an aggressive non-outage i
corrective maintenance backlog goal, which continues to challenge a not yet mature
twelve-week work management process. A selective sampling of two important
safety systems identified appropriate prioritization of open MWRs and no adverse
individual or cumulative effects of the backlogged preventive and corrective MWRs.
Planned and completed MWRs reviewed were properly documented and post-
maintenance testing was appropriate to the work performed.
- Surveillance and maintenance activities observed by the team were properly
performed with good procedural adherence, proper planning and execution, good
self-checking, and appropriate supervisory oversight. i
- Material condition and housekeeping at both units was generally good. Corrective
and preventive maintenance practices were appropriately defined and systems
performance monitoring for those systems within the scope of the Maintenance l
Rule was appropriate.
- The programs for the identification and disposition of control room deficiencies and
operator work-arounds was adequate. The licensee has recently created a multi- ,
disciplined Control Room Operator Deficiency team to help reduce the number of i
deficiencies. The tearn concluded that deficiencies were being properly identified i
for inclusion into these programs. l.
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- Appropriate procedural adherence was observed by the team and, in spite of the I
large backlog of procedure field revisions (~ 1800), administrative control and
issuance of procedures were in accordance with station guidelines.
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The training department personnelimplemented an adequate maintenance training
program, and appropriately maintained individual training records. Maintenance
technicians received the appropriate levels of training for performing selected
activities.
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- First-line supervisor oversight of field activities was observed to be good and I
maintenance management oversight and direction appropriate. Quality Assurance
audits were critical and a sampling review of the responses to adverse findings
were determined appropriate and timely.
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! TABLE OF CONTENTS
EX EC UTIV E S U M MA R Y . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . i
TA8LE OF CONTENTS ............................................. iv
1. Operations .................................................... 1
O1 Conduct of Operations ................................... 1 l
01.1 Control Room Observations . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 1 ]
02 Operational Status of Facilities and Equipment ................... 2
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03 Operations Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . 4
03.1 G e neral O bservations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ;
05 Operator Training and Qualification ........................... 5 ,
05.1 Requalification Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
06 Operations Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . 6 i
06.1 General Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 !
08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 l
08.1 (Closed) Violation 50-334 & 50-412/97-004-01. . . . . . . . . . . . . . 8
li. Maintenance .................................................. 9
M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
M1.1 Planning and Scheduling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
M1.2 Observation of Maintenance Activities . . . . . . . . . . . . . . . . . . . 11 l
M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . 12 ]
M3 Maintenance Procedures nd Documentation ................... 13
M5 Maintenance Staff Training and Qualification ................... 14
M6 Maintenance Organization / Administration and Quality Assurance of Activities
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V. M anag ement M eeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
X1 Exit M eeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 i
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INSPECTIO N PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
PRO C ED U R ES R EVI EW E D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
ITEMS OPENED, CLOSED, AND UPD ATED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
LIST O F ACRO NYMS U SED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
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Report Details
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. Backaround j
Beaver Valley Units 1 & 2 remained at rated power throughout the duration of this
inspection. The team directly observed approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of operator and
maintenance activities. The Nuclear Regulatory Commission (NRC) Inspection Procedure
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93802, Operational Safety Team inspection (OSTI) was considered in the scope of review
for each section of this report.
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1. Operations j
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01 Conduct of Operations )
01.1 Cont')I Room O_bservations
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a. Insoection Scope
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The team observed control room activities to verify that operators were adequately
communicating important information among shift members, conducting appropriate
shift turnovers and maintaining operator logs,
b. Observations and Findinas
Communications
The team observed good communications practices by operations personnel. Three-
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way communications were routinely and consistently used and the phonetic
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alphabet was used in almost all communications. The team also noted that
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operations personnel consisten:ly used three-way communications over the phones,
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and while using the plant paging system. Communications did not degrade during
response to the alarms / annunciators.
Shift Turnovers
The team observed severa! watch stations / crews conduct turnovers. Sufficient
turnover time was allocated to ensure that plant status information was transferred
to *.he oncoming shift. Personal shift relief checklists were used by operators to
facilitate a comprehensive discussion of plant status. In addition to noting
equipment status ar d performing log reviews, the operators also conducted reviews
of degraded equipment, evr,lutions in progress, and plant configuration changes.
The team also notea that t.1ere was active participation by in-plant auxiliary
operators during the shif t turnover briefings. During the formal turnover period, the
Assistant Nuclear Shift Supervisor (ANSS), Nuclear Shift Supervisor (NSS), control
board operators, and the outside operators would present operability status of plant
equipment as a routine part of the turnover. The team verified the effectiveness of
shift turnovers through discussions with the operators and their supervisors. The
team observed that the shift meeting conducted following the shift turnovers met
the administrative requirements for the shift turnover meeting. However, it was
observed that sometimes information discussed during the shift turnover meeting
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was difficult to hear. Operations management addressed this by discussing this
- observation with shift staff and improvement in this area was noted.
Operator Loa Keepina and Rounds !
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The team found that the information documented in the computer based operator L
logs was appropriate and that the shift operating logs met administrative
requirements. The team accompanied the Unit 1 turbine building and the Unit 2 l
auxiliary building plant operators during performance of their routine building tours.
, The team found the operators to be knowledgeable of systems and familiar with the
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bases for the log readings they recorded. In the event that an out of specification
reading was noted, the control room was immediately notified. Housekeeping
- issues, identified by the plant operator, were discussed with the ANSS at the
completion of the operator's rounds.
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c. Conclusions
Operator actions observed during this inspection were all conducted in a safe and
j controlled manner in accordance with plant procedures. Operations personnel
consistently adhered to management standards and expectations regarding
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communications, and control board awareness. Three-part communications, peer
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and self-checking were routinely used by the operators. The team observed several
shifts turnovers and concluded that tumove,rs were effective in ensuring that the
operators were wellinformed of plant conditions, and that important plant status
information was conveyed to the oncoming shift. Non-licensed operators did an
, excellent job taking plant logs and addressing plant deficiencies during the shiftly
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rounds. Log keeping practices were consistent with the administrative
requirements.
02 Operational Status of Facilities and Equipment
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a. Inspection Scoce !
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The tearn reviewed the safety tagging and equipment control processes to verify
that they were adequate to protect workers and to control the status of safety-
related equipment. The team also reviewed the process for controlling keys for
locked plant equipment and area access.
b. Observations and Findinas
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Eauioment Safety Taaaina
The clearances reviewed were thoroughly documented, tags were accurately
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interviewed were familiar with the clearance and tagging requirements. During plant
walkdowns, several tags were selected by the team for confirmation of accurate tag
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placement and description. No discrepancies were identified. The team also noted
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that no safety-related configuration control errors, by operations, have been !
identified during the past 19 months.
Ooerability Status of Safetv-Related Eauioment !
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The team observed conservative decision making in entering Technical
Specifications (TS) Limiting Conditions for Operations (LCOs) when taking
equipment out-of-service. Operations shift management had employed rigorous
controls on entering TS LCOs. Potential LCO entry determinations were reviewed
and agreed to by the NSS, ANSS and the shift technical advisor prior to taking ,
actions,
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The team reviewed the open Bases for Continued Operation (BCOs) for Unit 2. The l
BCOs reviewed were verified to be consistent with Nuclear Power Division
Administrative Procedure (NPDAP) 5.7, Basis for Continued Operation, Rev. 2 and i
NRC Generic Letter 91-18," Resolution of Degraded and Nonconforming
Conditions." The justifications for the BCOs reviewed were technically sound and
well documented. i
Control of Maintenance Activities
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The control room operators were aware of ongoing activities in the plant that could
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affect plant equipment and control room indications. The team noted that i
appropriate questions were asked by the control room operators about the planned ,
work during pre-evolution briefings. For example, shift operators noted that a
planned maintenance activity to identify a direct current electrical ground would
l result in disabling the local carbon dioxide alarm in the area where the work was
being performed. Operators chose to postpone this activity until the personnel
safety issues were addressed. During off-normal conditions and testing evolutions,
shift management provided briefings to the operating crew. These observed
briefings were Generally concise, accurate, and timely. During discussions and pre-
job briefs, the operators were attent;ve and actively participated.
Kev Control Process
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The team reviewed the key control log and the overall administration of keys. The
team noted that all keys were accounted for and that those which were missing
from their designated storage cabinet location (both those keys used for operations
department equipment and those used for entry into high radiation areas) were
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I The team noted two minor discrepancies with the administration of the key control
process. The Administrative Assistant is to inventory the key cabinets and sign that
they have done so after each shift. In practice, the night shift NSS performs the
inventory during the back shift. The team also noted an out-of-date list of staff, ,
authorized to access keys, was included in the back of the key control log. The list
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was no longer part of the key control process and was removed from the log. A
Condition Report was written to address the key inventory review discrepancy. j
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c. Conclusions i
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The safety tagging requirements established for maintenance activities were
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appropriate. The recent change to a computer based clearance tagging process was
noted as an enhancement. The implementation of the safety and configuration
tagging administrative requirements by plant operators was effective.
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The present process for monitoring the status of equipment / components was
appropriate. Operations shift personnel employed rigorous controls on entering a s
Technical Specification Limiting Condition for Operation. The control room staff was i
well informed of ongoing activities in the plant. The shift management provided !
appropriate oversight of shift activities and pre-evolution briefs were well organized. ,
Additionally, the team concluded that the Bases for Continued Operation for Unit 2 )
were completed in a manner consistent with NRC guidance. j
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The key control practices observed were acceptable. The minor administrative
discrepancies noted by the team were addressed by the operations staff.
03 Operations Procedures and Documentation
03.1 General Observations
a. Insoection Scope
The team verified that the control and use of operations procedures was consistent
with administrative requirements. A sample of plant and system operating
procedures was reviewed to verify that the procedures were of adequate quality.
The team also assessed the quality and usage of procedures by observing the
performance of plant evolutions. The team reviewed the operations procedure
revision process and assessed the control of the procedure revision backlog.
b. Observations and Findinas
Procedure Quality
The team noted that a large backlog of recommended procedure revisions had not
been incorporated into the current operating procedures. The licensee had
prioritized the backlog of procedure revisions into three categories. At the time of
this inspection, the backlog of Priority 1,2, and 3 revisions was approximately 900,
457, and 1548, respectively. In addition, there were approximately 130 condition
reports which also required procedure changes. The licensee was in the process of
developing a plan to reduce the backlog of procedure revisions.
The most significant procedure revisions, priority 1, are referred to as operating
manual change notices (OMCN) and are expeditiously incorporated as temporary
"on-the spot" changes to the procedures. Priority 2 revisions are referred to as
operating manual change requests (OMCR) and are incorporated into the procedures
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on an as-needed- basis prior to the next conduct of the procedure. The priority 3,
OMCR revisions are considered procedure enhancements.
The team verified that the backlog of pending procedure revisions was properly
prioritized by sampling recommended procedure changes for five risk significant
systems. The team also verified that the control room procedures requiring priority
2 revisions were identified as such, with the use of a yellow cover page that stated
that a revision to the procedure was required prior to use. The team did not identify
any deficiencies in the quality of the procedures selected for review or with the
control of pending procedure revisions.
Procedure Comoliance
The team observed appropriate procedural compliance by operations personnel.
Routine use of " repeat-backs," verifications, and peer / independent reviews prior to
actions performed was noted. Alarm response procedures were referenced and
followed on an as-needed-basis in accordance with the Conduct of Operations
Manual. The team observed that operating and surveillance test procedure steps
were carefully and correctly followed. The team observed good verbatim procedure
compliance.
c. Conclusions
The team concluded that overall procedure adherence / usage was excellent. The
quality of the procedures reviewed was aduuate. Operators were aware of
management's expectations for procedure compliance. A large backlog of
recommended procedure revisions exists. The large backlog of recommended
procedure revisions indicated the need for a more focused effort to incorporate
these changes to enhance the overall quality of operations procedures.
05 Operator Training and Qualification
05.1 Recualification Trainina
a. insoection Scoce
The team verified that licensed operators were attending routine requalification
training in accordance with the licensee's Training Administrative Manual.
b. Observations and Findinas
The team reviewed the requalification training records for the 1998 licensed
operator training cycle for both units. The annual requalification cycle consisted of
six training modules, which are repeeted six times to ensure that all of the operating
crews received the training. The team reviewed the individually signed attendance
records for a sample of modules and cross-referenced those records with the
computer-based status records for each operator. The status records accurately
reflected the specific training that had been received by each of the licensed
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operators. In the case where an individual had not completed a given class within a !
module, a makeup class was given and documented as such. The team reviewed
the status records for each of the licensed operators and confirmed that all
operators were current in their requalification training for the 1998 training cycle,
c. Conclusions
A review of 1998 cycle requalification training records indicated that licensed
operators for both units were up-to-date with their required annual requalification
training and were completing their requalification training in a timely manner. I
06 Operations Organization and Administration
06.1 General Observations
a. Inspection Scope
The team verified that the operations department was providing adequate shift
staffing and guidelines for maintaining appropriate operators at the controls. The
team also verified that plant management was providing operations staff with clear
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expectations, setting proper standards, and conducting effective oversight of
operations activities,
b. Observations and Findinas
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Shift Staffina
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The team noted during control room observations that operations shift management
appropriately maintained the required operators at the controls and controlled the
access of non~ operating personnel to the " controls area" of the main control room. l
When one board operator left the controls area, there was appropriate !
communications to ensure the remaining board operator was fully aware of the l
absence. The team verified that control room staffing was appropriate for the
current mode of operation. Interviews with operators indicated that they were
familiar with the staffing requirements and the standards and expectations provided
in the Conduct of Operations Manual. The team reviewed shift personnel ,
assignments, control room staffing, and fire brigade assignments. The shift l
manning practices were appropriate and complied with TS.
Manaaement Standards and Oversicht
Plant management standards and expectations for the operations staff were
provided in the Beaver Valley Power Station Unit 1 and 2 Operations Standards." ;
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'- These standards cover a range of areas including reactivity management,
conservative decision making, communications, and control room conduct and
command and control. The Operations Standards clearly delineate management's
expectations in a procedure format to be used in conjunction with the Conduct of 1
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Operations Manual.
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In order to communicate standards and expectations, the General Manager of
Nuclear Operations conducts lunchtime meetings, on a weekly basis, with the
operation's crew attending annual requalification training. During these meetings,
expectations are discussed and feedback from operations management is provided
to the operators. Additionally, the General Manager of Nuclear Operation meets
with the NSS and ANSS personnel bi-weekly to discuss expectations and provide
feedback. The team observed good management oversight of daily operations !
activities in the control room, by both the General Manager and the Operations l
Managers. ,
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Operation's management also used shift night orders to provide expectations to
shift operators. The team reviewed a sample of the shift night orders and verified
that the information provided was consistent with administrative guidance.
The team found that the NSS and ANSS provided appropriate oversight of shift
activities. Prior to plant evolutions that had the potential to afferd plant equipment,
shift supervision discussed contingencies with the reactor operators. Additionally,
pre-evolution briefs conducted for the surveillance tests were well managed.
c. Conclusions
The licensee has appropriate requirements established for operators working in the
" controls area" of the main control room. The team noted that these standards
were met during control room observations. The team found that the NSS ar'd
ANSS, as well as operations management, provided appropriate oversight of shift
activities. Management's standards and expectations have been clearly established i
in procedures, during routine crew lunchtime meetings with the General Manager of l
Nuclear Operations, and during the bi-weekly meetings with shift supervision.
07 Quality Assurance in Operations
a. Inspection Scoce
The team reviewed several 1998 Operations Department self assessments to
evaluate the quality of the self assessment program.
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b. Obserrvations and Findinas i
Tnere were nine operation's self assessments scheduled for completion during
1998. The operation's department had completed seven self assessments and the
remaining two self assessments were planned to be completed before the end of
the year. The team reviewed four completed self assessments in the areas of
equipment clearances, Unit 1 reactor trip, TS surveillance testing, and operator
administrative burdens.
The equipment clearance self assessment was conducted approximately one month
prior to implementing a new computer-based clearance process. The self
assessment provided a detailed description of the new clearance process, but due
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to its timing, did not provide meaningfulinsights of performance in this area. The
self assessment conclusion was that another assessment of this area should be
conducted following the implementation of the new process. The self assessment l
schedule was appropriately revised to reflect this recommendation.
The stated objective of a self assessment conducted following an August 1998 Unit
1 trip was to assess operator performance during the event. However, the self l
assessment conclusions did not document an assessment of operator performance i
during this event. The self assessment did not document any weaknesses or I
recommendations. The Operations Support Manager stated that a detailed review
of the trip, including recommendations, was conducted in accordance with the
corrective action program. The team concluded that the stated objective of the self
assessment was satisfied by another program and little additional value was added
by conducting this self assessment. ,
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The TS surveillance program self assessment documented the corrective actions
completed in response to an NRC Notice of Violation. The focus of this self
assessment was narrow and the conclusion of the assessment did not provide
, program performance insights or recommend improvements.
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A self assessment of operator administrative burdens was conducted by polling the
operators for inappropriate operator administrative burdens. The operators provided
several examples where they believe that administrative burdens could be reduced.
The Operations Manager took prompt action and issued guidance to implement
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several of the recommendations of this self assessment. The team noted that the
licensee had established appropriate guidelines for tracking weaknesses and
recommendations generated during the self assessment process. i
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c. Conclusions
The team concluded that while the self assessment program satisfied administrative
- requirements, the operation's self assessments reviewed did not consistently
provide management with worthwhile operator performance insights or recommend
improvements.
08 Miscellaneous Operations issues
08.1 1 Closed) Violation 50-334 & 50-412/97-004-01: failures to promptly identify
conditions that were adverse to quality, including an inoperable service water pump,
i two trains of supplementalle sk collection and release system concurrently out of
j service, and incomplete shift operating logs. The team noted that logging of
I unusual evolutions, tests and potential effects on the facility's TS and operability
status, were routine and kept current (i.e., "real time" accessability) with the use of
the computerized logging si stem. These computerized logs were also readily
available to the supervisors for review and were used as a shift turnover reporting
mechanism. System statu s was also routinely reviewed by the on-coming .
supervisors. For example, recent emergency diesel generator (EDG) testing
procedures highlight reviet v of an opposite train's component conditions prior to
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l performing any testing of any EDG The equipment operability determinations made i
l by licensed operators during this inspection were appropriate and timely. The team i
l found that the corrective actions for the violation adequately addressed the issues l
and the violation is closed.
11. Maintenance
M1 Conduct of Maintenance
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M 1.1 Plannina and Schedulina
a. Insoection Scooe
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The team interviewed various work management department personnel to evaluate
if existing processes were adequate for planning, scheduling, and implementing
maintenance and surveillance activities. The team also attended routine work
management meetings and reviewed recent performance trend data to assess the
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effectiveness of the work management processes. The team reviewed the nature
l and extent of the backlog of corrective and preventive maintenance activities,
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discussed current backlog reduction goals and expectations with station
management, and reviewed recent performance indicators to assess backlog
reduction efforts. Additionally, the team reviewed the maintenance backlog for two
risk-significant systems to verify that no equipment operability issues existed, and
that backlogged items were adequately tracked and prioritized. The team examined
the quality and completeness of planned and completed maintenance work requests
(MWRs). !
b. Observations and Findinas
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Review of Twelve-Week Plannino Process
The work management process is based on a twelve-week planning process, in
which work activities are systematically planned over the twelve-week period before
the date of scheduled execution. Station procedure, NPDAP 7.12, "Non-Outage
Planning, Scheduling, and Risk Assessment," describes the methodology for the
! twelve-week process. Work management department personnel completed plc .,iing
their first twelve-week cycle in July 1998. From discussions with department
personnel, the team noted that many planning milestones described in NPDAP 7.12,
such as " freezing" the schedule and identifying operational post-maintenance tests
(PMTs), were often not met. For example, the team observed that a PMT following
corrective maintenance on a Unit 2 emergency feed water valve was not completely
planned. Specifically, work management personnel did not identify the required
u steps to be performed in the PMT procedure. Unit 2 control room operators spent
i
-considerable time determining the appropriate steps to be completed during the
PMT, thereby delaying the performance of other scheduled activities.
From a review of recent work management performance data, the team noted
improvements in process implementation. Based upon October 26,1998, weekly
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work process performance indicator data, MWR schedule adherence (MWRs
completed versus planned for the work week) had risen to approximately 60 to 70
percent from about 40 percent in July. However, work management department
personnel indicated that work activities were frequently dropped from the schedule,
due to unplanned challenges or incomplete planning. Technical Specification
surveillance testing and preventive maintenance (PM) schedule adherence remained
high, at approximately 98 percent.
The team reviewed several work week critiques prepared by work week managers
following completion of each twelve-week planning cycle. Work week managers
provided self-critical performance assessments by identifying process strengths and
weaknesses. However, the team noted that other work management personnel
such as planners, schedulers, and senior reactor operators were not familiar with
the issues identified in the critiques, and were not involved in the self assessment
process.
MWR Backloa Review
The backlog of non-outage corrective maintenance (CM) MWRs consisted of
approximately 1,2OO items between both units. The present goal for the station is
to reduce the non-outage CM backlog to less than 800 items by the end of
December 1998. To reach this goal, DLC personnel must work off approximately
20 backlog items per week at each unit. Recent performance indicators showed
that the CM backlog has remained relatively constant since the implementation of
the twelve-week work process in July 1998, thereby demonstrating that weekly
goals have not been met. The Maintenance Manager stated that inefficiencies in
the twelve-week work management process and manpower support issues have
been contributing factors. At the time of this inspection, DLC personnel were
developing plans to meet backlog reduction goals. For example, DLC personnel
were assigning more lower priority MWRs to the contractor workforce. The team
also reviewed the PM backlog, and noted that the backlog was very small, only a
few items at each unit.
The team reviewed the maintenance backlogs for two systems with high safety
importance (Unit 1 river water system and the Unit 2 high head injection system).
Examination of individual MWRs, including follow-up discussions with the
responsible systems engineers and a review of the cumulative impact of the
outstanding MWRs, identified no adverse operability concerns or evidence of
improper prioritization of planned or corrective maintenance. The vast majority of
the outstanding MWRs for both systems required a unit outage to accomplish.
Monthly Maintenance Rule (MR) system reliability and availability reports provided
evidence of appropriate efforts to maximize system availability. Quarterly MR
reports of (a)(1) and (a)(2) systems overall health, prepared by the Performance
Engineering Department (systems engineering staff), similarly provided evidence of
routine system performance monitoring and trending. Based on discussions with
the associated systems engineers, the team noted that the systems engineers
accurately tracked the backlog items, and applied sound bases for prioritizing the
outstanding corrective and preventive MWRs.
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MWR Packaae Review
From a sampling of approximately 60 closed MWRs awaiting records storage, the
team conducted a detailed examina*n of six MWRs involving completed corrective
rnaintenance on both safety and non-dafety related components performed between
May 15 and September 19,1998. The team identified clear documentation of the
identified problem, proper step-text corrective actions to address the problem, and
appropriate PMT to demonstrate system operability. The closure documentation
appeared to be complete and in accordance with maintenance department
administrative procedures.
The team examined six planned corrective MWRs which were prepared for future
work-week system outages at both units. The packages were likewise complete,
with clear descriptions of the problem and proper step-text or referenced
maintenance procedures to accomplish the planned work activities. One of the
planned MWRs (No. 075202) involved future troubleshooting of the Unit 2 service
water heat exchanger outlet isolation valve,2SWS*RQ100B. The MWR
appropriately bounded the scope of the allowed troubleshooting and stipulated the
conditions for subsequent repair and return to service.
c. Conclusions
The efforts to reduce the sizeable CM backlog have not been fully effective. Station
management established an aggressive non-outage CM backlog goal, which
continues to challenge a not yet mature twelve-week work management process. ,
A selective sampling of two important safety systems identified appropriate )
prioritization of open MWRs and no adverse individual or cumulative effects of the
backlogged preventive and corrective MWRs. Planned and completed MWRs
reviewed were properly documented and post-maintenance testing was appropriate
to the work performed.
M1.2 Observation of Maintenance Activities
a. Insoection Scope
The team observed corrective maintenance, preventive maintenance, and
surveillance testing activities performed during the on-site incpection period to verify l
the activities were properly planned, controlled, and performed in a manner
consistent with plant procedures and standards. I
b. Observations and Findinas
The team observed a number of planned work activities during the on-site l
inspection and verified that the activities were properly executed per the daily and
weekly maintenance schedule. The team observed pre-evolutionary briefings,
control room operator work release reviews and work crew interactions (including
protective tagging), supervisory and engineering staff oversight, and system
restoration. The team noted good procedural adherence, attention-to-detail, and
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good self-checking techniques used by the work crews. Communications amongst
the work crew members, and between the crews and the first-line supervisors and ,
control room staffs were very good, with frequent use of repeat-backs and )
acknowledgments. The work activities were performed at an appropriate pace to )
ensure proper execution of the tasks and to minimize system unavailability. Work ;
crews were knowledgeable and familiar with the job tasks.
c. Conclusions
Surveillance and maintenance activities observed by the team were properly
performed with good procedural adherence, proper planning and execution, good
self-checking, and appropriate supervisory oversight.
1
M2 Maintenance and Material Condition of Facilities and Equipment
a. Insoection Scope
The team assessed the adequacy of the material condition of the plant, including a j
review of identified maintenance deficiencies to verify that the condition of plant l
equipment was acceptable. The team also reviewed the programs for the control i
and disposition of control room deficiencies and operator work-arounds to verify j
'
that operator responsibilities for these programs were properly implemented.
b. Observations and Findinos
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Plant H_ousekeepino and Material Condition
The team conducted a number of plant tours to assess the general material
condition and housekeeping of both units. Overall housekeeping was found to be
adequate. Several minor discrepancies were noted and promptly addressed by the ,
licensee. A few instances were observed where tools and/or protective clothing l
were left at a job site and not properly returned to in-plant storage areas. The team !
noted that the housekeeping in Unit 1 was superior to that observed at Unit 2.
Material condition of equipment at both units was generally good. Observed
discrepancies were properly tagged for f Jture repair or replacement. No significant
equipment problems were identified.
The team reviewed the MR 10CFR50.65(a)(1) systems at both units to verify that
the licensee had properly implemented goal setting and monitoring for those
systems which had exceeded system reliability and/or availability criteria. For the
current (a)(1) systems at both units, performance goals were conservatively
established for transferring these systems back to (a)(2) status. Monthly status
reports were prepared by the MR staff, as well as, quarterly systems' " health
reports" by tl ;, Performance Engineering Department staff, Discussions with
responsible systems engineers confirmed their awareness of historical and ongoing
(a)(1) and (a)(2) systems' performance issues and the planned preventive and
corrective maintenance activities targeted on the twelve-week schedule. No
concerns were identified by the team in this area.
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Control Room Deficiencies and Operator Work-arounds
The programs for identifying and tracking control room deficiencies and operator
work-arounds were incorporated into the Conduct of Operations Manual. At the
time of the inspection, there were 26 identified control room deficiencies for Unit 1
and 18 deficiencies for Unit 2. A computer database was used to track the status
of each deficiency and performance indicators were used to track performance
against established goals. The current goal per unit is to have less than 12 control
room deficiencies by December 31,1998. The licensee has recently created a
multi-disciplined Control Room Operator Deficiency (CROD) team to help reduce the
number of deficiencies. The team meets on a monthly basis to review the
deficiency lists, assign action items with due dates, and assign an " owner" for each
deficiency. Additionally, the CROD team intends to develop a separate procedure
for the control of CRODs in the near future.
The program guidance for tracking operator work-arounds includes a two priority
system. Priority 1 work-arounds include equipment deficiencies that impact
operator response during a transient, and priority 2 include deficiencies that impact
day-to-day operations requiring compensatory actions. Each of the units have two
priority 1 work-arounds. Units 1 and 2 have nine and sixteen priority 2 work-
arounds respectively. The team reviewed the work-around list and verified that the
items were appropriately categorized. While the status of the work-around items
was tracked, the team noted that the scheduled completion date for a number of
the items was annotated as "to-be-determined." The ide.ntification of operator
work-arounds was discussed with operations personnel and the team concluded
that deficiencies were being properly identified for inclusion into the program,
c. Conclusions
Material condition and housekeeping at both units was generally good. Corrective
and preventive maintenance practices were appropriately defined and systems
performance monitoring for those systems within the scope of the Maintenance
Rule was appropriate.
The programs for the identification and disposition of control room deficiencies and
operator work-arounds was adequate. The licensee has recently created a multi-
disciplined Control Room Operator Deficiency team to help reduce the number of
deficiencies. The team concluded that deficiencies were being properly identified
for inclusion into these programs.
M3 Maintenance Procedures and Documentation
a. Inspection Scope
The team examined the technical adequacy of maintenance procedures and verified
the approprP * 'ss and adherence to the administrative controls for revising
maintenance department procedures.
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4 b. Observations and Findinas
For the surveillance and maintenance activities observed by the team (listed at the
end of this inspection report), the reviewed and approved procedures used by the
work crews were appropriate to the tasks being performed. Field revisions
(permanent changes to the current revision) to procedures were properly annotated
in the margins and sections of the procedures which were not applicable to the
work being performed were properly N/A'd prior to issuance to the work crews, to
eliminate errors or misunderstandings during the actual performance of the work in
the field. Equipment performance data was properly recorded, and step completion
and place-keeping techniques were appropriately applied.
The team reviewed the maintenance department procedures field revision backlog
(approximately 1800 outstanding changes) which included non-intent and intent
procedure changes. The majority of these field revisions were non-intent changes
provided by the maintenance staff during the work planning and MWR review
phase. Interviews with maintenance workers and first-line supervisors confirmed
that they viewed positively the ease in which they could submit procedure revisions
to enhance their quality and accuracy. Discussion with the responsible procedures
control administrator and review of available trend data identified that the backlog
was slowly trending downward, but was limited by the available man-power and the
time intensive revision process, (estimated to be about 10 man-hours per field
revision) which currently includes an on-site review committee review, in
accordance with TS. The team confirmed that appropriate controls were in-place
for the issuance of maintenance procedures with the current field revisions
incorporated.
c. Conclusions
Appropriate procedural adherence was observed by the team and, in spite of the
large backlog of procedure field revisions (~ 1800), administrative control and
issuance of procedures were in accordance with station guidelines.
M5 Maintenance Staff Training and Qualification
a. Inspection Scoce
.
The team reviewed the maintenance training program and selected craft persons'
training records to verify that training was adequate for the level of work performed
by the individuals.
b. Observations and Findinas
The training department personnel maintained a detailed multi-disciplined training
program for maintenance technicians. The maintenance training program was last
evaluated in 1996, and was scheduled for an accreditation renewal evaluation by
the Institute of Nuclear Power Operations in 1999.
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f The team reviewed the training records for electrical maintenance technicians that i
, performed motor-operated valve testing during th9 inspection period, and noted that
the technicians received an appropriate level of training to perform the task at hand.
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The team also sampled recent maintenance training attendance records, and noted
that the training sessions were routinely attended by the required personnel.
Training department personnel appropriately rescheduled any attendance i
,
exceptions.
. c. Conclusions
i
The training department personnel implemented an adequate maintenance training
.
program, and appropriately maintained individual training records. Maintenance
4 technicians received the appropriate levels of training for performing selected !
activities.
M6 Maintenance Organization / Administration and Quality Assurance of Activities
a. Inspection Scope
The team examined the adequacy of the organization for overseeing maintenance
activities and self-assessing the effectiveness of maintenance processes. The
extent and quality of independent oversight in the maintenance area was also
reviewed.
b. Observations and Findinas
As observed by the team, the majority of direct oversight of maintenance performed
in the field was by first-line supervision. Interviews confirmed that workers were
comfortable with the level of direct involvement and accessability of first-line
supervisors and that more senior maintenance management presence in the plant
was more the exception than the rule. Maintenance managers interviewed by the
team stated that first-line supervisors were meeting oversight expectations, but that !
recent outage demands and organizational changes had adversely impacted senior j
maintenance managers' availability to directly oversee field activities. As discussed
in Section M1.1, MWR schedule adherence has not met established goals,
principally due to recently implemented processes and newly established work
interfaces. Management recognized the need for increased oversight and assigned
a new Work Management Department manager and support staff to facilitate the
desired work processes and staff performance improvements. The team did not
observe any appreciable adverse impact on safety-related equipnient availability or
reliability, as a result of the work management process inefficiencies.
The team examined a number of recent self-assessments and Quality Assurance
(QA) Department audits and surveillances performed in the maintenance area.
These assessments were found to be critical. The August 3,1998, Maintenance
Audit (No. BV-C-98-08) was critical of the maintenance department's performance
and identified a number of repeat problems from the 1997 audit in this area. The
team reviewed a sampling of the Condition Reports and maintenance department's
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dispositions to these audit findings and found them acceptable. A discussion with ,
the QA Manager identified that he viewed the maintenance management and staff
as responsive to QA's oversight and feedback, and that the repeat findings were
being appropriately elevated and addressed by senior management. A sampling of
recent surveillance reports found the QA staff oversight of maintenance activities to i
be quite comprehensive and appropriately documented. :
c. Conclusions
First-line supervisor oversight of field activities was observed to be good and
maintenance management oversight and direction appropriate.' Quality Assurance
audits were critical and a sampling review of the responses to adverse findings .
were determined to be appropriate and timely.
!
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V. Management Meetings !
X1 Exit Meeting Summary i
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On November 16,1998, a meeting, open for public observation, was held to j
discuss the findings of this inspection. DLC management present at the exit i
meeting did not dispute the team's findings or conclusions. Based on the NRC i
Region I review of this report, and discussions with DLC representatives, it was
determined that this report does not contain safeguards or proprietary information.
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.
INSPECTION PROCEDURES USED I
] IP 93802 Operational Safety Team inspection
PROCEDURES REVIEWED
l
Administrative Procedures
" Operations Standaro - Standards Section", Revision 22
i 1/20M-48.1.A, " Duties / Responsibilities of the Operations Group", Rev 15
1/20M-48.1.B," Operations Shift Complement and Functions", Rev 17
1/20M-48.1.C, " Shift Turnover and Relief", Rev 3 1
'
1/20M-48.1.D," Operations Shift Rules of Practice", Rev 0
1/20M-48.2.B," Control of Operating Procedures", Rev 16
1/20M-48.2.C," Adherence / Familiarization To Operating Procedures", Rev 1
i
1/20M-48.3.C," Padlocks / Locking Devices Admin Requirements", Rev 13
i
1/2OM-48.3.D, " Administrative Control of Valves / Equipment", Rev 18
j 1/20M-48.3.E, " Work Request Submitted (Orange) Tags", Rev 0
, 1/2OM-48.3.M, " Operator Work-Arounds", Rev 1
'
NPDAP 3.4, " Clearance /Tagout Procedure", Rev 9
NPDAP 5.7, Basis for Continued Operation, Rev. 2
,
NPDAP 8.29," Conduct of Self Assessments,"
!
Surveillance Procedures
,
20ST-1.1., " Unit 2 Rod Operability Test", Rev 3
-
2MSP-2.03-1," Power Range Neutron Flux Channel N41 Calibration", Rev 5
j Surveillance and Maintenance Activities Observed
- M071829,"1C recirculation spray heat exchanger inlet MOV lube and inspect"
- MO66374, " Unit 2 SLCRS trains A modification"
- 20ST-24.4, " Steam turbine driven auxiliary feed pump [2FWE*P22] test"
- 2MSP6.21-1, " Loop 2 RCS T422 channel test"
- 1/2OST43.17A, " Control room area monitor [RM-1RM-218A] functional test"
- M074891, " Calibration of delta-flux circuitry for N42, using calibration data from
- MPS 070862, " Preventive maintenance on the control room outdoor supply air
, . _ __ _ _ . _ _ .- _. _ -. .
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ITEMS OPENED, CLOSED, AND UPDATED !
! l
Closed I
j' 50-334 & 412/97-004-01 VIO Operations personnel failure to identify
conditions adverse to quality !
L !
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! LIST OF ACRONYMS USED
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ANSS Assistant Nuclear Shift Supervisor
BCO Basis for Continued Operation ]
CM Corrective Maintenance
'CR Condition Report
CROD
.
Control Room Operator Deficiency
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DLC Duquesne Light Company
EDG Emergency Diesel Generator {
l
l LCO Limiting Condition for Operation j
l .MR Maintenance Rule J
- MWR Maintenance Work Request - i
!
NRC Nuclear Regulatory Commission :
l -NSS Nuclear Shift Supervisor i
NPDAP Nuclear Power Division Administrative Procedure
l OMCN Operating Manual Change Notice {
l OMCR Operating Manual Change Request
! OSTl Operational Safety Team inspection .
PMT Post Maintenance Test
PM Preventive Maintenance
TS Technical Specification
QA Quality Assurance
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