ML20214W428
| ML20214W428 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/30/1986 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20214W359 | List: |
| References | |
| NUDOCS 8612100223 | |
| Download: ML20214W428 (19) | |
Text
.
ENCLOSURE
)
SEQUOYAH SER MAINTENANCE INPUT l
4 T
I.
Subject Inspections at the Sequoyah facility during 1984 and 1985 indicated deterioration of management controls over the maintenance program.
This negative trend was brought to the attention of the licensee-in the Systematic Assessment of Licensee Performance (SALP). The licensee's rating changed from a Category I for the period ending in February 1984, to a Category 3 for the period ending in May 1985.
6 The management breakdowns resulted in numerous program deficiencies.
I i
Although the licensee responded adequately to specific NRC concerns, r
o response to the root cause of the concerns and development of programmatic corrective actions was marginal and ineffective resulting in escalating NRC actions.
Specific program deficiencies included the following.
The licensee failed to take adequate corrective action for personnel errors with resultant increases in personnel errors.
Many of these personnel errors caused unnecessary challenges to reactor trip and engineered safeguards equipment.
I I
~
8612100223 861128 PDR ADOCK 05000327 O
PDR 4
2 Inadequacies in maintenance planning, training of craftsmen, post maintenancetestingandfieldsupeNisionofmaintenanceactivitieswerenot adequately corrected. The licensee failed to maintain accountability for work performance and failed to communicate job requirements and performance expectations to employees. Adequate 1.reventive maintenance programs were not established.
Trending of maintenance problems was not adequately implemented and, therefore, certain deficiencies in safety-related equipment maintenance and surveillance were not promptly corrected. The licensee failed to perform a comprehensive review of the Technical ' Specifications and Final Safety Analysis Report for surveillance and maintenance requirements resulting in failure to adequately implement these requirements.
II.
Summary of Issue By letter dated September 17, 1985, the NRC Executive Director for Operations notified the Chairman of the Board of Directors of TVA that the Systematic Assessment of Licensee Performance (SALP) indicated weaknesses in the Sequoyah maintenance program.
By letter dated November 1,1985, TVA responded to these concerns by submitting the Corporate and Sequoyah Nuclear Performance Plans (NPPs).
Part III, Section 6.0 of the Sequoyah Nuclear Performance Plan documents the review and evaluation in the area of plant maintenance as a part of the readiness review conducted by the licensee for restart of the Sequoyah tm i ts.
~
3 On July 17, 1986, the licensee submitted Revised Corporate and Sequoyah Nuclear Performance Plans.
Section II.4 of the Revised Sequoyah NPP discusses the maintenance program deficiencies and the corrective action taken and proposed by the licensee.
III. Evaluation The maintenance related commitments delineated in the Revised Corporate and Sequoyah Nuclear Performance Plans have been reviewed by the staff. These commitments are not substantially different than those presented in the.
November 1985 Corporate and Sequoyah Nuclear Performance Plans.
Onsite inspections were conducted in December 1985, February 1986, and September 1986, as documented in NRC Inspection Reports 50-327, 328/85-45 and 50-327, 328/86-18, and 50-327, 328/86-48 to evaluate implementation of these commitments, to determine maintenance adequacy and to assess management resources allocated to the administra' ion of the maintenance program.
Staff reviews indicate that the actions described in the Revised Corporate and Sequoyah Nuclear Performance Plans with regard to maintenance activities are, for the most part, being implemented. Significant deficiencies in the maintenance program will be corrected by the licensee prior to startup.
Many of these short term actions are completed as discussed below.
4 0
i 4
certain program weaknesses will, however, require long term corrective actions. The staff believes that those long term actions proposed by the licensee will correct program weaknesses that still exist. The staff will monitor the implementation of these actions. The staff's evaluation of long term corrective actions is also provided in the following discussions.
The licensee's Nuclear Management Review Group (NMRG) is conducting a i
comprehensive assessment of corrective and preventive maintenance practices at Sequoyah. Draft results of this review have been provided to the NRC for evaluation.
The licensee's corrective actions to address the root causes of the maintenance program deficiencies, i.e.,
inadequate management involvement and accountability, appear adequate.
The licensee has implemented the following specific actions:
j a.
Craft Related Management Deficiencies Meetings among line managers from the Group Supervisors level to the general foremen level have been established. -These supervisors have been directed to consider various indicators, determine specific i
problem areas and make assignments for the resolution of the problems.
Implementation of this policy will assure that specific managers are held accountable for resolution of defined problems.
i
(
I I
l
3 5
The Maintenance Manager's role has been redirected to require periodic communication of plant policy and requirements to employees.
The Maintenance Manager will attend monthly safety meetings with Instrument, Electrical and Mechanical Groups.
In addition, group meetings will be called and conducted by the Maintenance Manager to address personnel errors.
These actions will assure that upper management communicates job requirements, expectations of performance and feedback on poor performance directly to the working level.
Foremen will be assigned plant experience items for review with their crews during-weekly meetings.
Management instructions and correspondence will reinforce this review. Daily meetings between the foremen, general foremen and planners will continue to be used to improve coordination, preparation, and conduct of work.
The addition of a foreman to supervise the instrument maintenance section's backshift activities has alleviated the lack of supervision on the backshift and has improved the communications between the backshift and dayshift by providing for shift turnover between the two instrument maintenance foremen.
Permanent craft section supervisors have been assigned to each craft section.
This organizational change has freed the general foremen to become more involved in technical, day-to-day issues and to better address administrative duties and forward-looking programs.
0
+
O
6 b.
Knowledge and Implementation of Administrative Requirements The licensee has conducted a two day training course on administrative requirements including QA requirements, maintenance work control system, clearance procedures, temporary alterations and procedural adherence.
The licensee has also conducted update training for revisions to maintenance administrative instructions. The majority of required personnel have attended.
Non-attendees will be required to attend planned refresher courses on these topics.
4 c.
Accountability A revised program utilizing an Employee Performance Report (EPR) to track employee violations, personnel errors, failure to follow instru'ctions, and below average performance as well as above average performance, has been implemented. This tracking mechanism will allow managers to directly correlate work performance with performance evaluations on a quarterly basis.
These evaluations will assure that employees and managers are held accountable for their performance. The licensee has directed foremen to investigate instances of personnel errors within two weeks and reflect the results on the EPR including disciplinary actions.
NRC inspectors observed, however, that these actions have not yet been fully implemented.
The EPRs and quarterly evaluations have been discontinued in the mechanical maintenance section since February 1986.
Prior to February 1986, quarterly evaluations'were determined to have e
1 7
been inconsistent with the EPRs and, in most cases, th'e investigation of personnel errors and dischlinary actions exceeded the completion target of two weeks.
Correction of these inadequacies was identified as inspector followup item 50-327, 328/86-48-01 for subsequent staff review.
The licensee has reassigned crews such that implementation of specific surveillance instructions are assigned to a specific foreman and/or crews.
Specialized crews should become more proficient at their assigned tasks. The licensee will also be able to track accountability and direct corrective action more effectively.
The licensee has distributed a handbook delineating the responsibili-ties of the foreman. Additional inspections will be needed to confirm
. implementation of the handbook requirements specifically to assure that foremen have increased the level of direct job observation and supervision, d.
Revisions to Maintenance Work Control System The licensee has implemented a.new maintenance request system involving a tag / card system.
The system separates the process methods for safety-related maintenance and nonsafety-related maintenance and simplifies the processing of the nonsafety-related maintenance. These actions, when fully implemented, should allow further differentiation between nonsafety-related tasks and safety-related tasks, quicker 6
5
8 prioritization and processing, and reduce backlogs of maintenance requests. NRC inspectors noted an apparent discipline problem in the placement and removal of maintenance request tags which should be addressed by licensee management.
The licensee is developing a computer based work request supplement to reduce planning requirements for multiple craft jobs.
Revisions have also been made to the workcontrol program to facilitate processing ASME Section XI valve maintenance.
In the area of planning and scheduling of maintenance work, the staff believes that the licensee's new programs show potential for proper work management; however, due to the relative newness of program changes, additional implementation time is recessary to conclusively assess effectiveness.
The licensee has developed guidelines for planners on writing adequate maintenance request packages and determining required post :naintenance testing.
The staff notes that the licensee relies extensively on the expertise and knowledge of planners for all aspects of maintenance program implementation. The licensee has increased the staffing and training in this area, however, the lack of field walkdowns to determine if maintenance requests are adequate and not routinely providing information on recent plant modifications are considered weaknesses.
O u
i 9
The licensee has added a Senior Reactor Operator to coordinate the plannerk maintenance foremen and operations activities with personnel. This action should improve the maintenance work implemen-tation process, e.
Procedure Enhancements The licensee has issued a vriter's guide for maintenance instructions (MI) and has developed a detailed MI evaluation checklist for procedural enhancement.
The writer's guide is a detailed description of the format, organization and writing style to be used in rewriting all maintenance instructions.
The licensee has committed to a prioritized program to improve maintenance procedures; write new procedures for tasks which presently are replanned each time they are performed; and simplify work packages by reducing the number of interdependent procedures.
Priority one procedures will be completed by July 30, 1987.
The licensee has not established a completion date for priority two procedures.
The staf f's review of draf t maintenance instruction rewrites indicates that the maintenance instruction enhancement program will improve the quality and uniformity of maintenance instructions.
In addition, the licensee now requires each craftsman and foreman to review Mis prior to use, identify needed corrections, revise the procedure if necessary, and sign a review sheet documenting their review and suggestions.
Management assigns responsibility for e
10 revisions as appropriate.
The licensee will require craftsman or foreman ' review prior to issuEce of new procedures or significant i
revisions.
Field walkdowns will also be performed as the need is determined by management.
1 In the short term, the actions discussed above will assure that work packages and procedures are technically adequate prior to performance of the work and that the 'craf tsman understands the instructions.
Standards will be in place for new procedures to assure that technically adequate and clearly defined steps are provided to the j
craftsman.
Individuals will be held accountable for the adequacy of the procedures and for timeliness of the revision process.
I Long term actions will provide for a systematic evaluttion of maintenance instructions to clarify work instructions, factor in performance experience and correct human factors deficiencies that could lead to failure to follow instructions.
Further inspection in this area will be conducted as identified by inspector followup item 50-327, 328/86-18-06.
i f.
Establishing Preventive Maintenance Program I
In the past, the licensee has had a very weak preventive maintenance I
program due to the emphasis on reactive maintenance. The licensee has 1
]
implemented several measures to. strengthen the preventive maintenance program.
l
11 Organizational changes have been made in the maintenance area to staff the management positions with experienced, permanent mangers.
The licensee is also staffing a systems oriented Technical Support Systems Engineering Group to provide engineering support to the maintenance and operations departments.
The licensee intends to initiate the system engineering program in stages over a two year period.
Initially, walkdowns and trending techniques will ti developed for the essential raw cooling water and residual heat removal systems prior to Unit 2 startup.
These techniques will be expanded to 14 safety related systems approximately one month af ter Unit I startup.
At the completion of the two year period, the licensee plans to implement the program for the 33 safety related programs covered by the Design Baseline Verification Program.
Additional inspections will be needed to confirm the full implemen-tation of the systems engineering program as identified by inspector followup item 50-327, 328/86-48-02.
Within the maintenance department, a staff will be developed to identify problem areas and refine the preventive maintenance program to address these problems.
The manager of the trending staff has been assigned. The staff's review of trending program developtrent indicates that the planned program will be adequate to identify repetitive failures for preventive maintenance program revision.
f l
12 The licensee has committed to an increased effort in the development of preventive maintenance instru tions.
Administrative procedures have i
been revised to clearly address vendor recommendations for incorpora-tion into the preventive maintenance program. Specific inconsistencies in the preventive maintenance procedures should be resolved by the licensee as identified by unresolved item 50-327, 328/86-48-07.
The licensee has conducted a review of the Technical Specifications and the Final Safety Analysis Report to ensure that preventive maintenance requirements are met.
Management assessment of the review results t
should be completed prior to unit restart as identified by inspector followup item 50-327, 328/86-48-03.
l The licensee has also committed to establish a Reliability and l
l Performance Branch within the Department of Nuclear Engineering to implement a reliability centered maintenance program.
l l
i g.
Training i
The licensee has achieved INPO accreditation for the instrument maintenance area and is seeking accreditation for the electrical and 1
mechanical maintenance areas. The licensee has significantly increased the training program requirements including doubling hours of training 7
required for electrical and mechanical maintenance craftsmen and r
inclusion of training on problem areas identified during NRC 1
inspections and licensee reviews.
[
i
_ = _ -
i t
I 13 r
The licensee has dedicated the resources of the Sequoyah Power Operations Training Center Maintenance Training Unit to Sequoyah l
l training by staffing onsite maintenance training units at other sites.
1-t In the. short term, the licensee has already provided a significant amount of additional training to craftsmen, particularly on problem areas.
Long term actions will upgrade the program to INPO standards 4
and increase training quality and credit hours to higher levels.
e 1
h.
Programs to Address Specific Deficiencies i
r i
t
{
(1) The licensee has substantially completed a program to provide j
baseline verification data for motor operated valves (MOVs) i through the use of the MOVATS program. The licensee has committed to develop a comprehensive visual inspection, lubrication, and i
j testing program for MOVs with cross disciplinary crews to perform l
maintenance on the valves.
NRC inspections of the MOV program indicate that the licensee is implementing a high quality program. The staff believes that the MOV program Will provide the historical data and management i
1 controls necessary for comprehensive preventative maintenance to i-t increase the reliability of the MOVs.
The incorporation of MOV j
torque switch settings into, plant procedures has been identified l
t i
as inspector followup item 50-327, 328/86-18-05 for subsequent
[
\\
staff verification.
i r
i i
i
i 14 (2) To resolve problems with the calibration of measuring and test equipment, the licensee Es developed a computerized data base for M&TE, ettablished additional controls on the tracking and disposition of out-of-calibration evaluations and reduced evaluation periods.
The staf f has inspected the improvements in management controls in this area and found them to be adequate to resolve the deficiencies; however, a review of outstanding out-of-calibration evaluations since June 1986, indicated that the licensee has routinely exceeded the specified two week completion requirement.
The timely completion of out-of-calibration evaluation is considered mandatory and has been identified as unresolved item 50-327, 328/86-48-04 for subsequent staff review.
(3) The licensee has taken action to correct the procurement process to preclude the procurement and installation of class IE com-ponents without the appropriate seismic qualification documenta-tion.
All class IE replacement components currently in power stores that do not have appropriate seismic documentation have been identified, segregated and appropriately tagged to preclude future use in class 1E applications.
Approximately 125,000 maintenance requests were reviewed to identify all class 1E replacement components installed in the plant which potentially have the same seismic documentation problems.
This review iden-tified 138 replacement mild environment class IE components in this category.
This review of licensee actions to resolve u
i 15 potential qualification problems for these 138 components is identified as unresolved tem 327,328/85-45-18.
This item is a subset of the procurement problem identified in inspection report 50-327,328/86-61, and must be resolved prior to restart.
i.
Maintenance Startup Commitments The licensee has performed
- pre-startup checks of the status of plant equipment, reviewed outstanding maintenance requests on safety-related equipment and reviewed Potential Reportable Occurrence (PRO) Reports for adequacy of corrective maintenance activities.
The staff believes that these reviews have assured that essential equipment is operable and properly tested, and that any outstanding maintenance activities do not affect operability.
Further inspection will be conducted prior to startup to confirm satisfactory completion of the restart items identified during the PRO review as identified by inspector followup item 50-327, 328/86-48-05.
J.
Corrective Action for Repetitive Failures and Inadequate Trending During the maintenance inspections, pas weaknesses were noted in management assessments and actions associated with repetitive failure of safety-related equipment.
The timeliness associated with achieving full implementation of long term. actions and the lack of establishment of intermediate actions in light of continued questionable past system operability was considered inadequate. The staff attributes these past
~
i
.o 16 weaknesses to the failure of management to evaluate the operability of safety-related equipment and hstems which have a continued history of i
problems and poor performance.
Previous lack of adequate trending i
]
programs and lack of management support of the utilization of l
reliability data contributed to the program failures.
i In t'e case of the Upper Head Injection (UHI) System, the licensee has h
committed to evaluate UHI system past operability considering previous repetitive failures to meet isolation valve stroke times and level switch calibration acceptance criteria. The licensee has evaluated all other applications of Barton Model 288A differential pressure switches 3
and has provided adequate corrective actions for those applications determined to have been unreliable.
2 The licensee has reviewed all outstanding maintenance requests, design j
change requests and engineering change notices to ensure that system i
operability is evaluated and deficiencies corrected.
This review has i
been incorporated into the licensee's design verification program.
)
Completion of staff review in this area is addressed in the Safety 4
i Evaluation Report for design control.
1 l
The November 1,1985 Sequoyah Nuclear Performance Plan stated that a trending program would be developed based on INPO guidelines by December 31, 1985 and that a trending log of instruments to detect i
repeated out-of-tolerance conditions would be kept by the Instrument I
+
l l
e
-i
l 17 Maintenance Engineering Section. The revised SNPP issued in July 1986, states that the maintenance dhartment would be provided the personnel to maintain the trerding program.
The staff's review of the trending program indicates that, when fully implemented, the provisions for trending equipment failures and component out-of-calibrations should be adequate to identify repetitive problems. The licensee wiH submit the details of the trending program as a supplemental response to violation 50-327, 328/85-45-06.
The staf f has determined that additional licensee evaluation of past repetitive failures and out-of-calibrations which may not have been identified under the old trending program is required.
Additional staff review will be conducted in this area to verify implementation of an adequate trending program and resolution of past repetitive failures.
IV.
Conclusion The licensee has responded to the breakdowns in the Sequoyah maintenance program by submitting comprehensive. plans for evaluations of the problem areas and corrective actions for specific and programmatic deficiencies.
Actions required prior to startup of either unit will assure that safety-related equipment is operable and is tested and maintained in accordance with technically accurate procedures. These actions will provide the management changes and staff additions to effectively implement the e
O 18 maintenance program.
The licensee has also taken action to improve the performance of maintenance by hereasing supervision, establishing accountability at the craft and manager levels and increasing the training for craftsmen.
The staff has noted improvements with regard to the performance of maintenance and has verified completion of many of the Nuclear Performance Plan commitments.
The attitudes = of employees at the craft and first line supervisory level were observed to be good. Managers and craftsmen appeared to be in support of new management emphasis on the reduction of personnel errors and personal accountability for performance. Ofrect observation of maintenance activities reflected adequate use of procedures.
Reliance on skill of the craft for activities observed appeared to be in line with that noted at other Region II facilities.
Craft personnel were observed to be knowledgeable of tasks they were performing and foremen and general foremen were observed to be properly knowledgeable of work being performed or planned under their cognizance.
The staff notes that the role of planners is integral to effective implementation of the maintenance program and has verified that the licensee has implemented improvements in staffing, written guidance and training for the planners.
Additional assistance in the form of systems oriented engineering support and reliability oriented engineering support has been scheduled for implementation within acceptable time periods. The staff will 3
continue to review implementation of the new work control system to verify i
l improvements in the planning and scheduling of maintenance.
19 Further effort is required in the improvement of the preventive program, particularly in the establishment of base line requirements and recommendations and implementation of these requirements and recommendations into preventive maintenance packages.
The portion of the licensee's-effort
~
in this area entailing the review of the preventive maintenance program against the FSAR and Technical Specifications should be completed prior to restart and has been identified as inspector followup item 327, 328/86-48-03.
Long term corrective actions to enhance and clarify procedures, simplify administrative requirements and improve preventive maintenance by trending failures have been scheduled for cimpletion within an acceptable time period and will be supported by adequate resources.
h O
t e
6