ML20244B468
| ML20244B468 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/01/1989 |
| From: | Cheung L, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20244B454 | List: |
| References | |
| 50-271-89-80, NUDOCS 8906130126 | |
| Download: ML20244B468 (43) | |
See also: IR 05000271/1989080
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report No.: 50-271/89-80
Docket No.: 50-271
License No.: DPR-28
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Licensee: Vermont Yankee Nuclear Power Corporation Brattleboro, Vermont 05301
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Facility Name: Vermont Yankee Nuclear Power Station
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Inspection Conducted:
February 27 - March 10, 1989
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Inspectors:
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L. Sf Cheung, Senior Reactor Engineer, DRS
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Team Leader
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S. K. Chaudhary, Senior Reactor Engineer, DRS
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P. D. Drysdale, Reactor Engineer, DRS
R. M. Loesch, Radiation Specialist, DRSS
K. I. Parczewski, Senior Chemical Engineer, NRR
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E. H. Trottier, Project Engineer, NRR
Approved by:
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Strosnider, Engineering Branch Chief
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ivision of Reactor Safety
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Inspection Summary: A special announced Maintenance Team Inspection was performed
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at the Vermont Yankee Nuclear Power Station on February 27 - March 10,1989
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(50-271/89-80).
Areas Inspected: An in-depth team inspection of the Vermont Yankee maintenance
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program and its implementation was performed. The inspection ir.cluded a review
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of maintenance documents and observations of maintenance work in progress. The
inspectors used the NRC Maintenance Inspection Guidance, dated September 1988,
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and Temporary Instruction 2515/97, dated November 3, 1988.
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Results: Overall, the maintenance program and its implementation were found
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-to be adequate. Areas of strengths and weaknesses were identified and are
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outlined in the executive summary and discussed in the report. Appendix 3 to
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the report presents a listing of weaknesses with cross references to the
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applicable _ sections of the report. Appendix 4 is a list of three unresolved
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items identified during the inspection with similar cross references provided.
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One violation was identified involving failure to follow procedures
(50-271/89-80-04).
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EXECUTIVE SUMMARY
Background
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The Nuclear. Regulatory Commission considers the effective maintenance of equip-
ment and components a major aspect of ensuring safe nuclear plant operations and
has made this objective one of the NRC's highest priorities.
To this end, the
Commission issued a Policy Statement dated March 23, 1988 that states, "it is
the objective of the Commission that all components, systems, and structures
of nuclear power plants be maintained so that plant equipment will perform its
intended function when required. To accomplish this objective, each licensee
should develop and implement a maintenance program which provides for the peri-
odic evaluation, and prompt repair of plant components, systems, and structures
to ensure their availability."
To ensure effective implementation of the Commission's maintenance policy, the
NRC staff has undertaken a major program to inspect and evaluate the effective-
ness of licensee maintenance activities. This inspection was one of a series
being performed by NRC to evaluate the effectiveness of maintenance activities
at licensed power reactors. The inspection was conducted in accordance with the
guidance provided in NRC Temporary Instruction 2515/97 and the NRC Maintenance
Inspection Guidance. The temporary instruction includes a " Maintenance Inspec-
tion Tree" that identifies for inspection the major elements associated with
effective plant maintenance.
Scope of Inspection
The maintenance inspection at the Vermont Yankee Nuclear Power Station (VYNPS)
was initiated with a site meeting between the team leader and the licensee
maintenance superintendent and other representatives on February 2-3, 1989
where the scope of the inspection, including the function of the maintenance
inspection tree, was discussed. A list of requested site-specific information
was provided by the licensee in response to a letter dated December 27, 1988.
A copy of the attachment to the December 27, 1988 letter is included in this
report as Appendix 1.
A comprehensive pre-inspection submittal of information
based on this request was provided to the team leader by Vermont Yankee Nuclear
Power Corporation (VYNPC) on February 3,1989.
VYNPS was shutdown for an
outage in mid-February 1989, and remained shutdown during this inspection.
The NRC inspection team spent from February 13 to February 24, 1989 (two weeks)
preparing for on-site activities by inspecting the information submitted by the
licensee. The team conducted the onsite inspection at Vermont Yankee from
February 27 to March 10, 1989.
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The on-site inspection focused on the observation of maintenance work in
progress at the site and on licensee activities supporting this work, including
support provided by the engineering, training, and management organizations.
Maintenance activities selected for detailed review included equipment identi-
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fied in the probabilistic risk assessment (PRA) for a similar plant as having
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the potential for contributing significantly to core damage accident sequences
or to the reduction of the risk associated with plant operations. Other
maintenance activities were selected for inspection based on the scope of work
in progress during the inspection, recent failures of safety-related equipment,
special interest items, and NRC inspection experience.
A presentation of the Vermont Yankee Maintenance Program was given by the licensee
on February 27, 1989, following the entrance meeting.
The following items were
discussed during the presentation:
Preventive and Predictive Maintenance
Surveillance
Corrective Maintenance
Equipment Upgrades
Deficiency Reporting
Post-Maintenance Testing Criteria
Daily meetings were held by the NRC team leader with plant management and
maintenance supervision to summarize the inspection team findings and identify
areas where additional information was required. On the morning of March 9,
1989, a communication session was held during which each NRC inspector presented
significant findings to Vermont Yankee management. A summary of the inspection
team findings, including a presentation of an evaluated maintenance inspection
tree, was discussed with licensee representatives including management, super-
visors and engineers at an onsite meeting on March 10,1989 (see Appendix 2 for
attendees).
Results
The inspection team evaluated three major areas:
(1) overall plant performance
as affected by maintenance; (2) management support of maintenance; and (3) main-
tenance implementation.
Under each of these major areas, elements considered
important to the proper functioning of the area were inspected.
For each ele-
ment, the inspectors evaluated both the program and how effectively the program
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was implemented. The inspection results for each area are summarized in the
following paragraphs, and the weaknesses and unresolved items are listed in
Appendixes 3 and 4, respectively.
In addition, a violation regarding
documentation problems associated with calibration of tools is discussed in
Section 3.3.d.
Overall Plant Performance as Related to Maintenance
General plant housekeeping and control of maintenance work areas, equipment,
tools, and material were observed to be well suited for accomplishing mainte-
nance work dering the refueling outage.
Observation of maintenance work in
progress and review of completed work indicated that maintenance is being per~
formed by skillful, knowledgeable and competent plant personnel and contractors.
Maintenance work is well supervised and indicates that the standard for the
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quality of work is high.
This standard is reflected in a relatively low rework
rate for maintenance and repairs on plant systems.
The good housekeeping and
knowledgeable maintenance personnel are strengths in their maintenance program.
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-Management' Support of Maintenance
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Although overall management support at the corporate and plant levels for
maintenance appeared strong and effective, the inspectors could find no formal
or documented policy directive either at its corporate or plant level that
specified management responsibilities for the' review and appraisal of the
maintenance program and for industry initiatives for improving the program.
Nevertheless, the licensee's informal management oversight and feedback system
appeared to work well to assure safe and reliable plant operations. However,
the inspection team concluded that to assure'a consistent approach in mainte-
nance activities within.the maintenance department sub groups, to improve the
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quality and scope of feedback information, and to provide a baseline to assess
trends for the overall' maintenance program, the licensee needs to establish a
more formalized and documented set of program directives and to strengthen its
feedoack system.
The licensee's lack of a comprehensive formal maintenance plan that clearly doc-
uments objectives, policies, responsibilities, authorities, and accountability
weakens management's controls to assure effective mainteriance of the plant. A
clear, comprehensive program document would not only provide a consistent ap-
proach to_ maintenance activities, but would establish a baseline to appraise
the adequacy of the policy and its approach and to-measure its effectiveness.
Currently, the licensee's maintenance program is based more on the stability of
maintenance staff, their skill in their-trades and professions, and their knowl-
edge of plant. system characteristics that come with long-term experience, than
on formally and clearly established management controls. This area is
considered a weakness in the licensee's maintenance program.
The maintenance program as currently implemented has not been comprehensively
reviewed in a structured manner since its inception at plant start-up. Although
individual changes, upgrades, and adjustments have been made to the program on
- an as-needed basis, no plans are currently underway or scheduled in the near
future to systematically evaluate the program in the light of past experiences
and plant aging. The licensee indicated, however, that a review of maintenance
is in the planning stage, and will be implemented when finalized and approved
by management.
The licensee has a program to review the appropriateness and technical adequacy
of completed maintenance activities. However, these reviews are not being
completed in a timely fashion. There is a large backlog of completed Mainte-
nance Requests awaiting such review. Also, the maintenance department compiles
and trends equipment performance problems on a regular basis but this infor-
mation is not communicated to or reviewed by upper management. These are
considered weaknesses in the maintenance program.
The inspection team also concluded that the licensee's lack of effective policy
~and procedures for controlling and updating manufacturer technical manuals is
a weakness in the current maintenance program as implemented.
Licensee management has not established a program, goals, or the necessary
training for the use of PRA concepts in its maintenance activities.
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However, despite these weaknesses, the licensee has implemented an adequate
maintenance program.
Its adequacy-is reflected in the relative absence of
repeat corrective maintenance tasks, and generally effective predictive and
preventive maintenance activities. The strength of the maintenance organization
lies in its long-term, highly skilled, and dedicated employees _who are backed
by a dedicated and knowledgeable engineering and supervisory maintenance staff.
The licensee's failure to develop a comprehensive set of documents to formalize
and upgrade existing practices; thereby, providing an infrastructure capable of
sustaining future good performance in light of the certainty of staff turnover,
is considered the licensee's greatest weakness.
Vermont Yankee has adequate technical support to conduct maintenance activities.
Additional resources are available through the Yankee Nuclear Support Division
in Framingham, Massachusetts.
The licensee does not have a separate QC organization. They use a " Peer
Inspection" technique instead. This " peer Inspection" technique was found to
be adequate and effective in identifying deficiencies in the implementation of
the maintenance program. Additional oversight is provided by the onsite
presence of the corporate QA group.
Radiological controls are adequately integrated into the maintenance program.
The experience of the ALARA Coordinators is considereo a strength, as
evidenced by the dose reductions associated with the reactor head assembly.
Overall control of regulatory documents was considered effective.
The level
of review was generally adequate, although sufficient information was not
routinely included in the documentation to appreciate the scope and level of
review performed to close open items.
Maintenance Implementation
The licensee has developed a functional work control program. Work is planned
and scheduled in accordance with appropriate administrative procedures.
However,
the greater strength again appears to be in the professional attitude and
attention to detail shown by the staff.
The plant staff appear to be "self
starters" in striving to improve their plant's performance.
Indeed, the
inspectors noted the pride in load factor and availability data recently
compiled by Vermont Yankee (1984 established a world record for reliability and
1988 was the plant's second best operating year).
It was apparent that the
staff and management appreciate the role that judicious preventive and correc-
tive maintenance play in overall plant performance.
The licensee's post-maintenance test requirements are not proceduralized in
their administrative procedure and the licensee does not have an integrated
Master Equipment List. These are considered weaknesses in their maintenance
program.
Overall, the licensee has established a well functioning maintenance organiza-
tion. This organization has a well developed program for performing corrective
and preventive maintenance. The main strength of the organization lies in its
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highly trained and competent staff.
Careful selection and an effective training
program assure that contracted personnel are well qualified for performing their
jobs.
The contracted work is supervised and monitored in a satisfactory manner.
The failure trending program under development is well conceived and will probably
contribute significantly to improving the predictive maintenance program.
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Maintenance facilities were generally well centrolled, equipped, and maintained.
The inspectors noted that the layout and utilization of these facilities are
well planned, organized, and controlled throughout the plant to accommodate the
movement of maintenance materials and equipment. The existing administrative
controls over procurement, receipt inspection, storage, and issuance of materials
were adequate for ensuring that maintenance materials are properly available
when needed and issued properly for their intended use. The control of tools
and meter and test equipment was also adequate for supporting maintenance
activities; however, minor problems were identified in the documentation and
labeling of calibrated torque wrenches.
The licensee's staffing controls are generally effective, with a low turnover
rate for maintenance personnel. The management policy is to not tolerate poor
- performance or the use of drugs.
The maintenance training programs and their
implementation are well established and documented, with a test and qualification
process in place.
The Maintenance Inspection Tree
The inspection team's conclusions about the status of the plant's maintenance
program are indicated by colors (gr.een, yellow, or red) on the maintenance
inspection tree (Figure 1).
For parts II and III of the tree, the upper left
portion of each block indicates how well the topic of the block is described
and documented in the plant maintenance program, including adequacy of proce-
dures. The lower right portion of each block indicates the team's conclusion
as to.the effectiveness of implementation of the topic covered by that block.
Green indicates that the program is well documented or that program implemen-
tation is effective. However, even for blocks shaded green, some areas for
improvement may be indicated in the report. Yellow indicates a marginal but
acceptable condition and red indicates the topic is missing or the intent of
that portion of the tree is not being met by the maintenance activities.
Blue
indicates.the item was not evaluated or could not be properly evaluated due to
recent changes.
The inspection team concluded that the Vermont Yankee Station has developed a
maintenance program that implements the significant attributes of the mainten-
ance: tree.
The team identified a number of strengths and weaknesses that are
discussed in the report. Weaknesses represent potential problems or conditions
discussed for licensee evaluation and corrective action as applicable. As
weaknesses were identified by the inspection team members, they were presented
to licensee representatives for initial review and evaluation during the course
of the inspection.
Individual weaknesses are discussed in the appropriate areas
of the report and are summarized in Appendix 3 of this report. The licensee is
encouraged to conduct its own evaluation of maintenance-related activities using
the maintenance inspection tree with the objective of finding areas for improve-
ment not identified by the previous self assessment or this NRC team inspection.
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INSPECTION FINDINGS
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This report presents the inspection team's findings and conclusions regarding
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the Vermont Yankee Nuclear Power Station site maintenance program and its
implementation. The section numbers of this report do not correspond to the
numbering sequence of the Maintenance Inspection Tree (Figure 1).
1.
OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE (Direct Measures)
Scope
The objective of the inspection in this area was to assess overall plant per-
formance as related to maintenance by conducting plant system walkdowns, and
~ direct inspections of completed work and maintenance activities in progress.
The overal1~ level of personnel knowledge and management involvement in the
final work' product.were also assessed by these direct measures.
Findings
The inspectors conducted walkdown inspections of plant systems and maintenance
in' progress to~ assess the extent to which safe and effective work practices
were utilized by maintenance personnel. The inspectors also observed housekeep-
ing, and the arrangement and use of tools, equipment, scaffolding, temporary
support structures, system tag-outs, etc.
The inspectors toured areas used to
perform maintenance work on the emergency diesel generators, the CRD hydraulic
control units, feedwater/ condensate demineralized filters, 3A and 3B feedwater
heaters, the main. turbine generator, and the main condenser.
In all of these
areas, the inspectors observed that personnel were conscious of a need to
practice well disciplined work habits to maintain good housekeeping during and
after work hours, and to ensure that maintenance ecluipment, temporary struc-
tures, tools, barriers, etc., are used in a safe and efficient manner. Work
spaces were well controlled with properly designated personnel pathways, and
with well marked and posted hazard barriers. Temporary service leads (air
lines, water hoses, electrical lines, etc.) were arranged and secured in a man-
ner which enhanced work' activities without adverse effects in adjacent spaces
through which service leads were passing.
Specific tasks were conducted with
care to avoid damage to plant equipment from the tools and materials used to
perform maintenance.
Licensee safety inspectors were observed to be actively
inspecting plant work areas and temporary storage areas. The inspectors also
noted that contractor and technical personnel were generally very conscientious
about ensuring that the physical condition of plant components, systems, and
equipment were maintained at a high standard. A sense of ownership was evident
among these' individuals. Spot checks of system tag-outs revealed that tags
were clearly identified and the information on them was consistent with infor-
mation contained in tag-out logs maintained by the plant operation's group.
The' inspectors witnessed maintenance technicians generate-deficiency reporu
during the course of planned maintenance work to report previously unreported
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conditions. The deficient conditions were reported to the appropriate technical
groups for resolution.
Followup actions were initiated immediately so as not
to impair progress of the ongoing maintenance work. The inspectors observed
supervisory and engineering personnel visually checking deficient conditions
to ensure that corrective actions would be properly and completely specified.
Conclusion
General plant housekeeping and control.of maintenance work areas, equipment,
tools 'and material were well suited for accomplishing maintenance work during
the refueling outage. Observation of. work.in progress and review of completed
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work indicated that maintenance is being performed by skillful, knowledgeable,
and competent plant personnel and contractors. Maintenance work is well super-
vised and indicates that the standard quality of maintenance work is high.
This quality is reflected in the relatively low rework rate for maintenance and
repairs on plant systems. Good housekeeping ad knowledgeable maintenance
. personnel are a strength in the licensee's maintenance program.
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2.0 MANAGEMENT SUPPORT OF MAINTENANCE
The objective of this part of the inspection was to assess plant and corporate
management support of maintenance activities in the plant with respect to the
establishment, implementation, and control of an effective maintenance program.
The major areas evaluated were management's commitment to and involvement in
the organization and administration, resource allocation, and technical support
provided to the maintenance organization.
Discrete elements within these areas,
such as a documented maintenance plan, self-assessment measures, resource
allocation, definition of maintenance requirements, and accountability, were
evaluated to provide a basis for the team's overall assessment.
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2.1 Management Commitment and Involvement
Scope
The objective of this inspection area was to evaluate corporate-level and plant
management's commitment to and involvement in assuring the adequacy of plant
maintenance as indicated by:
(I) corporate level interest and participation in
.the continuing assessment and improvement of the maintenance program and its
support for industry initiatives; and (2) plant management's awareness of the
-status of the maintenance program and the implementation of maintenance activities.
Findings
The team evaluated these elements through extensive informal discussions and
formal interviews with plant and corporate staff, and reviewed the licensee's
planned, in progress, or completed activities with respect to INPO initiatives,
industry event communications, and the licensee's experience and data analysis
of plant performance.
-The corporate and plant management representatives interviewed indicated strong
support and interest in the proper performance of plant maintenance. Their
commitment to and support of improved maintenance was evident by the initiatives
implemented in this area in the recent past.
The licensee's two major initiatives to assess the effectiveness of its mainten-
ance effort and the safety of selected plant systems consisted of an extensive
self-assessment of the maintenance program (i.e., meeting INP0 guidelines), and
a safety system functional inspection (SSFI) performed by a contractor, which
was modelled on the NRC criteria for such an inspection. The licensee's SSFI
covered emergency power supply (onsite diesel generators) and high pressure
coolant injection systems (HPCI). The licensee has implemented structured
actions-to implement improvements recommended in the self-assessment report.
Weaknesses identified and recommendations made in the SSFI report are currently
undergoing licensee review and evaluation.
Licensee management appears to be
taking the findings of both reports seriously, and is trying to implement the
recommendations within the constraints of available resources and in view of
the relative safety significance of the weaknesses identified.
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The licensee also participates in the Nuclear Plant Reliability Data System
(NPRDS) and routinely uses NPRDS to enter and retrieve equipment failure data._.
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The engineering support personnel indicated that the information retrieved was
used as an ' analytical tool to determine the root cause of failures.
.Through interviews with plant personnel and a review of documentation, the
-team determined that the licensee informally used plant performance indicators
(meeting INPO guidelines) to assess the effectiveness of plant maintenance
activities.
.The team determined that plant management closely monitors the performance of
maintenance activities through informal methods of communication and feedback.
Conclusions
Although overall management support at the corporate and plant levels for
maintenance -appeared strong and effective, the team could find no formal and/cr
documented policy directive either at its corporate or plant level that specified
management responsibilities for the review and appraisal of the maintenance
program and/or industry initiatives for improving the program. Nevertheless,.
'the licensee's informal management oversight and feedback system appeared to
work well to assure safe and reliable plant. operations. However, the team
concluded that to assure a consistent approach in maintenance activities'within
-the maintenance department sub groups, to improve the quality and scope of
feedback information, and to provide a baseline to assess the trend of the
overall maintenance" program, the licensee needs to establish a more formalized
and documented set of. program directives and to strengthen the feedback system.
2.2 Management Organization and Administration (Corporate and Plant)
Scope
The objective of inspection in this area was to assess the effectiveness of
the organization and administ7 tion of the maintenance department and the main-
- tenance program, respectively.
The specific areas inspected to provide a broader
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perspective of maintenance activities included:
the existence, availability,
and scope of a formal maintenance program; maintenance policy, goals, and-
objectives; allocation of resources; and identification and definition of
maintenance requirements.
The team evaluated these areas to provide a basis
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for the overall assessment and conclusions.
- Findings
The team found that Vermont Yankee Nuclear Power Station does not have a unified
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comprehensive.' document or set of documents that clearly spells out policies,
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objectives, and all other elements of the plant's maintenance program.
Instead,
the program is currently scattered in various administrative and departmental
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policies, procedures, and instructions.
The program's organizational structure
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and personnel responsibilities, duties and accountabilities, including flow
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charts, are described in various documents. Moreover, the team could not
identify any formal corporate directive _or plant policy statement requiring
that a comprehensive maintenance plan be established, regularly reviewed for
applicability, and updated when necessary.
Key program components, such as
accountability, program description and purpose, data use, feedback, and
criteria for program changes, are not clearly described and/or cannot be shown
in a readily understandable form because of the lack of a unified and clearly
documented maintenance program. Although the elements characteristic of an
adequate maintenance program appear to be well implemented, they are not readily
apparent from documented procedures.
A review of current outago maintenance activities and the routine non-outage
activities of'the previous operating cycle indicated that the licensee has
allocated sufficient resources in manpower and material to the maintenance
organization for it to efficiently perform its function. The licensee relies
on contractor support for labor intensive activities and for unfereseen non-
routine activities during outages and other high activity periods. However,
the contractor personnel are well supervised and controlled by the plant's
regular staff.
Although they have not established a clearly defined and described maintenance
program, the licensee has implemented an adequate program of preventive, pre-
dictive, and corrective maintenance (CM).
Some of the noteworthy major initia-
tives in maintenance include use of the MOVAT system in predictive analysis for
valve performance; routine preventive maintenance (PM) and testing of safety-
related circuit breakers; comprehensive traiaing in basic skills and upgrades;
and work planning of complicated maintenance activities.
The maintenance department in the recent past established new positions for a
Maintenance Planner (temporary position) and a group of Maintenance Engineers
(one senior maintenance engineer and four maintenance engineers). The Mainte-
nance Planner position was filled by a licensed senior reactor operator to
provide increased operational insight in planning and scheduling maintenance
work. This appointment appears to be an effective way to enhance communications
with the operations department and should better prioritize maintenance work to
support safe plant operations.
The addition of the maintenance engineers to the staff has provided increased
technical support for reviewing predictive and preventive maintenance. The
maintenance engineer serves essentially an advisory role and their recommenda-
tions are provided to the maintenance supervisor.
The maintenance engineers'
authority, responsibility, and accountability are not formally established and
appear to be more on mutual understanding between the maintenance supervisory
and engineering staffs.
Although a more formal definition of activities and
responsibilities may be desirable, the informal working relationship that has
been developed appears to work well.
In the area of defining maintenance requirements, the team observed that the
licensee has not performed a comprehensive and structured review of the applic-
ability and adequacy of the plant's maintenance requirements.
It appears that
the maintenance requirements established at the time of initial aperations still
remain the basis of the overall maintenance plan. Although many improvements
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and new initiatives have been implemented to upgrade plac maintenance, the
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efforts appear to be on a piece-meal basis without any coherent review of the-
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plan as a whole. The licensee has a program to review the appropriateness and
technical adequacy of completed maintenance activities. However, these reviews
are not being completed in a timely fashion. There is a large backlog of
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completed Maintenance Requests awaiting such review. .The above two areas (plant
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maintenance requirements and review of.recently completed PM and CM activities)-
'
are weaknesses in their maintenance program.
In spite of the lack of programmatic review and assessment of the maintenance
!
program, licensee management has implemented formal and informal measures to
1
assess the effectiveness of maintenance activities. Maintenance supervisory
and management personnel regularly perform walkthrough inspections and. sample
maintenance in progress, review the results of surveillance performed to
.
!
determine the operability of systems to satisfy plant technical specifications,
i
and review the-root cause analysis performed by the plant engineering sup'
i
group. They also use plant performance indicators as a measure of mainte._.ce
effectiveness.
!
The maintenance department has tracked and analyzed data on performance of
equipment from 1972. However, this information is not formally documented and
there is not an established mechanism, except a memorandum from the maintenance
engineer to the maintenance supervisor, to disseminate the information to higher
- management or to pursue an issue,--as in the case of an adverse trend. The
inspectors noted that in many cases, the trend graph showed a rise towards the
acceptance limit (DG-1-1B; SW pumps; SW system as a whole; FPFD system; RWCU
system; core spray system), but that there was no formal plan available indicat-
i
,
ing the existence of a longterm program to reverse the trend. Also, there was
)
no documented evidence that these analyses had been communicated to plant or
'
corporate higher management for their review and evaluation.
l
.The inspectors also observed that there was no effective mechanism to update-
manufacturer's technical manuals for equipment despite the fact that some manu-
'facturers provide an approved procedure specifying the process for controlling
-formal revisions of their manuals.
Formal revisions of manufacturer technical
manuals were infrequent in part, due to the fact that manufacturers do not
widely distribute revisions to old customers on a consistent basis.
In some
,
!
cases, the information on a particular piece of- equipment is developed at other
,
sites and received by the licensee through other channols.
The team noted that.
I
information received by the licensee in manuals, other than a formal technical
!
manual revision, was filed separately from the manuals for which they were
!
intended, and these files were not controlled.
Such a filing system makes
determining the validity and/or currency of information contained in the
i
controlled manuals very difficult.
The potential also exists for missing
_ updated information regarding the validity or effectiveness of planned main-
!
'
tenance on an' item. That this is a weakness in the licensee's maintenance
program as currently implemented.
i
_ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _
1
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13
.
.
1
Conclusions
Based on the above findings, the team concluded that the lack of a comprehensive,
formal maintenance plan clearly documenting objectives, policies, responsibilities,
authorities, and accountability, is a weakness in the management controls the
licensee has instituted. A clear, comprehensive program document would not only
provide a consistent approach to maintenance activities, but it would establish
a baseline to appraise the adequacy of the policy and its approach and to measure
its effectiveness. Currently, the licensee's maintenance program is based more
on the stability of their maintenance staff, their skill in the trade or profession,
and the knowledge of the plant system characteristics that comes with a long
term job experience, than on formally and clearly established management controls.
U
The maintenance program as currently implemented has not been comprehensively
reviewed in a structured manner since its inception at plant start-up. Although
individual changes, upgrades, and adjustments have been made to the program on
an as-needed basis, no plans are currently underway or scheduled in the near
future to systematically evaluate the program in the light of past experiences
and plant aging. The licensee, however, indicated that a review of maintenance
is in the planning stage and will be implemented when finalized and approved by
management.
The appropriateness and technical adequacy of current maintenance activities
are not being reviewed in a timely fashion. There is a large backlog of
completed Maintenance Requests awaiting such review. Also, the maintenance
department compiles and trends equipment performance problems on a regular
basis but this information is not communicated to or reviewed by upper manage-
ment. These are considered weaknesses in the maintenance program.
,
The inspectors concluded that the licensee's lack of an effective mechanism
for updating manufacturer technical manuals is a weakness in the current program
as implemented.
However, despite these weaknesses, the licensee has implemented an adequate
maintenance program.
It's effectiveness is reflected in the absence of repeat
corrective maintenance tasks and generally effective predictive and preventive
maintenance activities. The strength of the maintenance organization lies in
,
its long term, highly skilled, and dedicated employees who are backed by a
'
dedicated and knowledgeable engineering and maintenance supervisory staff.
2.3 Technical Support
l
The inspectors evaluated the technical support the maintenance organization
receives from other parts of the organization, such as Engineering, Health
Physics, Quality Assurance, Quality Control, Fire Protection, and Operations.
The evaluation consisted of a review of the licensee's established policy, goals,
and objectives and an assessment of their effectiveness. The team selected
,
maintenance-related items from generic PRA, Licensee Event Reports, and generic
l
issues identified by NRC and industry sources, and evaluated how the maintenance
and other organizations interacted on these issues.
l
,.
. . .
i.'
.
.-
,
- ..
,.
2.3.1
Internal Corporate Communication Channels
' Scope
'
The objective of this inspection element was to evaluate the licensee's organi-
l
zational communication systems to assure that corporate policies for the
I
maintenance organization are incorporated into plant procedures and that a
feedback system has been established so that maintenance concerns are identified
to management for their information and action as required.
.'
Findings
Plant management and interested organizations are made cognizant of maintenance
!s
- concerns in daily meetings and through the review of Maintenance Requests
which are issued in accordance with procedure AP-0021 to correct the identified
deficiencies or problems. The most important means for communicating maintenance
and refueling concerns were the daily outage meetings, chaired by the Outage
l
Manager and attended by top management and representatives from each site
I
organization The meetings were held during the outage to discuss.the status of
current work and to properly plan, prioritize, and coordinate pending outage .
. activities. The inspectors attended several of the meetings and noted their
effectiveness.
The inspectors reviewed the licensee's established methods for communications
between Maintenance and Engineering to support maintenance activities. The
' team interviewed the Engineering Support Supervisor and an Engineering Program
Manager. The inspectors also reviewed various procedures and selected maintenance
requests to determine the depth and scope of communications with and support
from Engineering.
The inspectors found that corporate (offsite) Engineering and the resources of
the Yankee Nuclear Support Department (YNSD) are involved in maintenance on an
as-needed basis.
The resources of YNSD are not directly accessible or used in
day-to-day plant activities. Maintenance and site Engineering Support request
technical assistance only through their appropriate program managers at the
corporate level.
Conclusion
I
The inspectors concluded that the licensee's organization exhibited strong
communications in response to maintenance and outage related issues. The daily
meetings were effective and productive.
2.3.2. Engineering Support
'
Scope
'l
The objective of this part of the inspection was to evaluate the extent to which
engineering principles and evaluations are integrated into the maintenance
process.
This was accomplished by reviewing work orders, activities concerning
unusual events, failure analyses, and other maintenance activities to evaluate
the effectiveness of Engineering Support.
!
!
- -
)
. _ _ _ _
__
- _ _ _ _ _ _ _ _ _ _ _ _ _ _
______-__-_-____ _ _ -
m .:
-
' '
.
.
~
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15
.
.
4
Findings
The Engineering Support Department (ESD), corporate program managers, and YNSD
provide.the primary engineering resources for maintenance activities.
Day-to-day activities are handled by engineers within the maintenance department,
with additional support being provided from ESD or the corporate office on an
as-needed basis. YNSD services are coordinated by the corporate program managers
and are therefore not directly accessible to the plant staff, although close
informal communications are maintained between YNSD and cognizant plant personnel.
-To evaluate the support provided by both ESD and YNSD to the maintenance depart-
- ment, the inspectors reviewed component substitution, material upgrades and
. dedication, 50.59 reviews, and design change requests. These reviews indicated
that adequate engineering support is provided for maintenance activities. How-
'ever, the inspectors noted that no. formal training program has been established
in the methodology for performing root cause analysis.
During a plant tour, the inspectors.noted that paint was peeling.from large
areas of the upper drywell, with some areas exceeding a foot in diameter. The
inspectors questioned the potential.for the loose paint to clog the ECCS suction
screens in the. torus.
In response, the licensee stated that this paint peeling
issue had been identified previously and that an engineering evaluation had
been performed by-YNSD.
Because of. narrow net positive suction head margins
for the ECCS pumps, YNSD recommended that Vermont Yankee remove the loose paint
before each restart,. This loose paint removal process was instituted into the
VY prestart checklist.
The inspectors raised the concern that the loose paint
may build up fast enough during the 18 month operating cycle, and that the
post accident environment may cause additional peeling to fall down.
This
paint peeling may eventually get to the suction of the ECCS pumps to cause
clogging problems.
The licensee stated that they would evaluate and address
this concern after completion of this inspection. On May 12, 1989, the inspector
called the licensee regarding this issue.
The licensee stated that the' paint
peeling problem has been evaluated, and the evaluation has been reviewed and
approved by VY.PORC. The analysis of the paint chips indicated that the paint
pieces will break up into fine pieces, so small that they will pass through the
pump suction screens and core spray nozzle without causing clogging.
This is
an unresolved item pending NRC review of licensee evaluation (50-271/89-80-01).
As indicated in the transmittal letter of this report, the NRC has requested
that the licensee provide their basis for closing this issue within 30 days of
receiving this report.
Conclusion
. Engineering Support to the maintenance process has been well integrated. A
particular strength is the resources available from YNSD. However, management
attention is needed to: (1) establish a formal- root cause analysis program
-and (2) resolve the potential problem for loose paint to clog'the ECCS suction
screen.
(;;
- _ _ - - - _ _ - - - - _ _ _ _
- -
-
-
. _ .
- -
_
____--_ -
- - __ _ _ -______ - _ - _ - _ -
_ - _ _ _ _ _ -
'..y
-. ,
r u.;
.
16
c
..
2.3.3 Role of PRA in the Maintenance Process
.
Scope
..
The objective of this.part of'the inspectior was te determine the extent that
probabilistic risk assessment (PRA) concepts are censidered in the maintenance
program and in such areas'as planning, scheduling, and pricritization of work.
The inspectors' reviewed licensee activities related to the application of PRA
to the maintenance program.
~
Findings
.The licensee has neither a formal documented program nor goals for the inte-
gration of PRA into the maintenance program, although the licensee is aware of
those systems which have the potential to have a major impact upon plant safety.
Conc 1u'sion
Licensee management has. not established a. program, goals, or the necessary
training for the use of PRA concepts in plant maintenance activities. The team
examined the maintenance activities of selected PRA-significant systems and
components and found them.to have effective maintenance and technical support.
2.3.4
Role of Quality Control
Scope-
-The objective of this part of the inspection was to determine the extent of
,
. Quality Control (QC) involvement in the maintenance process. The inspectors
reviewed the licensee's procedures for implementing the QC surveillance program
and. trending of findings. The inspectors held discussions with QC personnel,
and reviewed work packages'and QC inspection plans for appropriate hold points.
Findings-
Quality control and independent inspection at Vermont Yankee is implemented at
the department level rather .than being performed by a separate QC organization.
The concept is referred to as'the " Peer Inspection" program.
The scope and
direction of QC inspections are determined by individual department supervisors
and are performed by independen: inspectors who are ANSI N45.2.6, Level II
qualified and who are not directly responsible for the work being reviewed. QC
inspection criteria are either incorporated into specific maintenance procedures
or job-specific QC attributes, and are developed and documented in a QC Inspec-
tion Report. The Department Heads annually review departmental QC performance
and forviard recommendations to the Plant Manager.
-The' inspectors reviewed several maintenance request packages, associated main-
tenance procedures, amplifying instructions, and QC attribute lists (Inspection
i
Reports). The inspectors also observed QC inspections in progress during the CRD
scram discharge valve diaphragm replacement work. The QC checklists and reports
reviewed by the inspectors addressed the important elements of the activity and
contained the appropriate QC hold points and sign-offs.
l
. _ _ . . _ - - _ _ - _
_
____--_-_ - -_.-_-__--_ - _---____-_-_.-_--_-__- _ _.-__ _ _ - - -
l
.
. _ _ -
.
. - -
__
- __
_ _ - _ _
-
'
.
.
.
~
.
17
,
.
Conclusion
Although the licensee coes not have a separate QC organization, the " Peer
Inspection" concept appears adequate and effective in identifying deficiencies
in the implementation of the maintenance program. Additional oversight is
provided by the onsite presence of the corporate QA group.
2.3.5 Integration of Radiological Controls into the Maintenance Process
Scope
.
The objective of this part of the inspection was to determine the coordination
and integration of radiological controls into the planning and performance of
maintenance work.
The inspection included a review of the "As low As Reasonably
Achievable" (ALARA) steps that are incorporated into planning for maintenance
work as well as the ALARA practiced as work was performed.
Findings
The licensee has established policies and procedures to integrate radiological
controls and ALARA principles into the maintenance process.
All Piant Design Change Requests, Engineering Design Change Requests, Plant
Alteration Requests, Maintenance Requests, Work Requests, and Installation and
Test Procedures are reviewed for ALARA concerns by the ALARA Engineer. Work
schedules during the outage were published daily and the Radiation Protection
Supervisor attended the daily outage management meeting.
Radiation Work Permits (RWPs) are the controlling documents for work performed
in the Radiation Controlled Area. Jobs with exposure estimates greater than 1
man-rem require the authorization of the ALARA Engineer and those greater than
10 man-rem require approval of the ALARA Committee.
The integration of radiological controls into the maintenance process was
conducted in accordance with plant policies and procedures. The RWP procedure
currently allows work in areas less than 100 mr/hr. Work expected to exceed
one man rem can be performed without an RWP.
This is considered an area where
improvement can be made.
However, the inspectors noted that a more conserva-
tive approach was taken in the actual issuance criteria for RWPs.
Dedicated ALARA Coordinators review work requests and evaluate the need for
job-specific ALARA reviews. The interdepartmental coordination between Radia-
tion Protection, Maintenance, and Operations was particularly noteworthy with
respect to reactor nead disassembly and reassembly.
The detailed review and
cooperation resulted in an overall exposure reduction for reactor head dis-
assembly from approximately 8 man-rem for previcus job evolutions to just under
3 man-rem during this outage. This substantial reduction in radiation exposure
is considered a strength in their maintenance program. However, additional
exposure reductions could be realized relative to the manual unshackling of the
moisture separator shield blocks.
,
Observations of work in progress indicated that job coverage by the RP technicians
L_____.______
_ - - - _ - - - -
.
_-____ _ _____ _
__
_ _ _ - _ _ _
_
-_
_ _ _ _ _ _ _ _ - - -
3;
.a
w
.
5. . . .
.
18
>
"
..,
,
-!
i
was adequate and that workers were sensitive to compliance with RWP requirements.
The-team- noted, however, that- the breathing zone air (BZA) samplers used by the
' licensee were inappropriate in-that they were affixed with a vortex separator.
The vortex separator, designed for use by the mining. industry, only measures
" respirable" particles (those less than 5 microns in size) and therefore may
not represent true air concentrations. After discussions with the licensee, the
vortex separators were removed from all BZAs to more accurately sample air
concentrations of radioactive materials.
Another area of concern involved fuel movement and drywell access controls.
3
Allowing personnel access' to the upper areas of the drywell (above the N2
{
feedwater nozzles and biological shield) while noving a peripheral fuel bundle
q
to its maximum elevation adjacent to the vessel flange could result in lethal
exposures to personnel.if a postulated fuel drop accident occurs simultaneously.
This concern was first documented by General Electric (GE) in an Operating
Experience Report (0ER No. 78), dated May 31, 1973, and again in a Service
Information Letter (SIL No. 354), dated February 18, 1981. .Even though'the
licensee performed a detailed evaluation and verification of the GE information,
they currently allow full access to the upper elevations of the drywell during
fuel' movement. Although' additional radiological controls (alarming dosimeters -
and remote detectors) are required in the drywell during fuel movement, unaccep-
tably high exposures could still result during the time it would take to
evacuate ie, upper drywell areas. The licensee committed to reevaluate admini-
strative utrols during fuel movement. This is an unresolved item pending
NRC review of licensee's resolution to this issue. (50-271/89-80-02)
Due to the potential for high radiation levels to workers in the traversing
incore probe (TIP) room, the licensee has implemented an additional level of
control by allowing Radiation Protection to request a tag out of-the TIP drives
prior to work. RP incorporated tM s as a_ requirement in their TIP room entry
procedure. The inspectors reviewed.the implementation of the controls associated
with an actual TIP room entry. Since the electrical breaker for the TIP drives
had previously been tagged out to RP for general work in the drywell, the work
group _ requested permission from RP to be added to the existing tag as an additional
work party leader in lieu of generating another tag. The inspectors noted
subsequent to the work that control room personnel had failed to update the
tag-out log to indicate the additional work party. The tag could have been
cleared and the equipment energized with workers still in the room. The inspector
also noted that procedure AP-0140, "VY Local Control Switching Rules," does not
address how to add an additional work party to an existing tag. The licensee
stated they will evaluate the need to strengtban controls in this area. This
is an unresolved item pending NRC review of fic nsee evaluation and corrective
action.
(50-271/89-80-03)
Conclusion
Radiological controls are adequately integrated into the maintenance program.
The experience of the ALARA Coordinators is considered a strength, as evidenced
by the dose reductions associated with the reactor head disassembly. Additional
management attention is warranted in the following areas:
the controls for
access to the upper levels of the drywell during fuel movenient, and the adminis-
trative control of tag-outs as it applies to an additional work party.
- - _ _ - _ _ _ _
_ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - _
.
. _ _ - _ _ _ _ _ _ _ _ _
. . ,
.,
..
..
19
,
.
!
2.3.6
Integration of Regulatory Documents in the Maintenance Process
Scope
$
The objective of this part of the inspection was to determine the methods used
to integrate regulatory documents in the maintenance process and to change these
documents as a result of periodic reviews and updates.
Findings
Regulatory documents are initially processed by the Licensing Engineer at the
.
plant and tracked as licensing action items (LAIs). Applicable documents requir-
ing action are forwarded by the Licensing Engineer to either the corporate office
or to the site for resolution. All such documents are also processed through
the Assessment Coordinator for record keeping and final assignment to the
appropriate department superintendents.
The licensee's current backlog of only 46 open regulatory items indicates an
aggressive approach to the identification and resolution of these items. A
sampling of commitments shows that the responsibility for resolution is clearly
assigned. Personnel assigned these items were aware of their responsibilities
and management was aware of the status of each item. The inspectors' review of
previously closed items indicated a generally adequate level of review, although
the documentation provided in many packages was minimal.
NRC Information Notice 87-66, " Inappropriate Application of Commercial Grade
Components," which specifically addresses safety class Agastat time-delay relays,
received minimal review and documentation. The documentation provided in this
package consisted only of the statements that there was "no impact on plant
operation or safety" and that the "QC program at VY prevents the occurrence of
similar events or problems." No information as to the scope or depth of the
review was provided.
Inspectors followup indicated that the responsible engineer
had examined the procurement system and verified that the appropriate Agastat
model numbers and safety class designations were currently entered into the
computer tracking system.
However, the licensee did not verify any previously
installed components to identify if a problem had existed. The inspectors per-
formed a spot examination of various safety and non-safety-related Agastat
relays. All safety-related components had the appropriate model numbers, al-
though one safety-related Agastat time-delay relay was found to have been in-
appropriately documented in the licensee's safety-related IE Instrument List
as a General Electric HFA relay. The licensee made the approriate changes to
update the list. The licensee also checked the rest of the instrument list and
did not find any additional errors.
Conclusion
l
Overall control of regulatory documents was considered effective. The level of
'
i
review was generally adequate, although sufficient information was not routinely
l
provided to adequately document the scope and level of review performed to close
open items.
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ -
_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
j
(.
.
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.
l
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20
.
,
3.0 MAINTENANCE IMPLEMENTATION
'
The purpose of this part of the inspection was to determine the effectiveness
of the established maintenance controls and, more importantly, the quality of
work performed.
The controls established in four areas were evaluated: work
control (Section 3.1), plant maintenance organization (Section 3.2), maintenance
facilities equipment and materials controls (Section 3.3), and personnel control
(Section 3.4).
The team evaluated effectiveness through observation of work
in progress and a review of completed work orders, procedures, and other
documentation associated with maintenance and training of maintenance personnel,
work in progress, tools in stock, spare parts, and held discussions with all
levels of personnel.
3.1 Work Control
Scope
The objective of this inspection area was to evaluate the effectiveness of the
maintenance work control process to assure that plant safety, operability and
reliability are maintained. The inspectors evaluated the following areas:
(a) Review of work in progress
(b) Control of work orders
(c) Equipment maintenance records
(d) Job planning
(e) Work scheduling
(f) Post-maintenance testing-
(g) Completed work control documents
Findings
(a) Review of Work in Progress
The inspectors observed work in progress on the main turbine and a standby
diesel generator. While on the turbine deck, the inspectors noted the mainten-
ance procedure and technical manual were in evidence and being used.
Discus-
sions with the turbine repair supervisor found him to be knowledgeable about
plant requirements (although he is a contractor), as well as about technical
issues.
In preparation for maintenance on the "B" diesel generator, the plant staff
conducted a timed start of the engine. While a plant operator was in the
engine room to perform pre-start checks and prelube the engine, no operating
procedure was in evidence. The inspector noted that the engine lube oil level,
air receiver pressure, jacket water temperature, and several other routine
pre-start checks were made, and that the operator was in communication with
the control room for engine pre-lube and starting instructions.
Subsequent
discussion with the licensee revealed that their procedure was kept in the
control room and that prerequisite (pre-start) checks are confirmed by
telephone with the operator at the diesel engine.
_ _ _ - _ - - - -
L ..
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4
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21
,
After the engine was successfully started, run approximately 3 minutes and
shut down, the inspectors noted that the engine was not barred over (turned or
cranked with no intent to start) as recommended by the diesel generator technical
manual. Subsequent discussions with the licensee revealed that a conscious
decision not to bar the engine over had previously been made by plant management
as a matter of Technical Specification compliance. The Technical Specifications
require demonstrated operability following any action or event that renders a
diesel generator inoperable. To bar the engine over after each run as recommended
by the manufacturer, the engine would first have to be blocked from responding
to any automatic start signal that might be received during the 1- or 2-minute
barring operation. A literal interpretation of Te:hnical Specifications would
require a demonstration of operability (engine start) after the auto start block
was removed.
Following engine shutdown, the manufacturer's recommended barring
should be performed, but the engine auto start feature would again have to be
blocked, which would lead to another operability run.
In weighting the options
available to them, plant management chose not to follow the engine manufacturer's
recommendation for proper engine care in favor of strict Technical Specification
compliance.
In response to the inspectors' questions, the licensee stated that they had
discussed this issue with the engine manufacturer and that they were pursuing
the manufacturer's recommendation of an " air roll" after shutdown to enhance
engine reliability and longevity. The licensee has added this modification to
their list of future work items. Addition of this " air roll" feature will also
allow the licensee to bar over the engine during pre-lube as recommended by the
engine turbine manual.
The inspectors had no more questions regarding this issue.
The inspectors observed corrective maintenance being performed on the "B" diesel
generator. The corrective maintenance was made necessary wher, scratches were
found on two camshaft lobes during an engine inspection in late 1987.
Following
the discovery of camshaf t distress, the "B"
diesel generator was placed on the
work list for the current (RF014) refueling outage. In the interim, a special
monitoring program was begun to detect deteriorating performance (if any) through
changes in cylinder temperature (No significant changes in engine performance
attributable to camshaft wear were noted).
Replacement camshafts (eight sections)
and associated parts (gaskets, nuts, washers, etc.) were concurrently ordered.
In reviewing the work packages, the inspectors noted additional parts associated
with the camshaft replacement were special ordered from the engine vendor after
the work was begun.
This is an example where maintenance planning could be
improved by considering repair parts availability.
The inspectors also observed the performance test conducted on 125-Volt battery
"A".
The discharge test was being conducted in accordance with Technical
Specification Section 3/4, Part 10.2.c, which states in part, "Once each op-
erating cycle, each station 125 Volt battery shall be subjected to a rated
load discharge test."
However, such discharge testing is never recommended by
the battery manufacturer, nor by Section 5.2 of IEEE Standard 450-1980, item 2.
The IEEE Standard, which is used to schedule the discharge testing of other
station batteries, recommends a performance test frequency of every 5 years.
l
It was noted that station battery "A" appeared to be new.
(The inspectors were
,
advised that the battery was replaced in 1985, then discharge tested in 1987,
l
in accordance with item 1 of IEEE Standard 450-1980, Section 5.2.)
l
1
l
- __-_-_-_-_ - ____ _ _
.
__ _
- - _
- _ - _
_
-
_ - _ _ _ - _
._
= _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -
.
.
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.
.
22
,
,
1
The inspectors raised the concern that excessive and unwarranted discharge
testing of station batteries may be, in the long term, detrimental to the
battery reliability.
(The 125-Volt station batteries are safety related.)
While such testing is required by plant Technical Specifications, the relia-
bility of safety-related equipment may be compromised by administrative, not
technical requirements.
To address this concern, the licensee stated that a Technical Specification
change is being. considered. This change would demonstrate continuing battery
operability by a service test which follows the specified emergency load
profile, performed every or alternate refueling outage, with a performance test
conducted every 5 years.
Such testing should enhance battery reliability and
longevity, while demonstrating that actual load requirements are met.
In the
interim, battery operability is demonstrated in accordance with Technical
Specifications and therefore there is no immediate safety concern.
(b) Work Order Control
The inspectors reviewed the licensee's method of work order control. The vehicle
used to control maintenance is the Maintenance Request (MR), which may be
initiated by any member of the plant staff or management. The MR form is com-
prehensive and has provisions appropriate to all foreseeable circumstances.
Each MR bears a unique sequencing number, as well as the initiator's name and
date. Appropriate blocks are provided to guide the MR through the review process
and adequate space is provided for necessary written descriptions.
Provision
for the performance of emergency maintenance is provided by telephone review
and concurrence from the Engineering Supervisor.
In addition, the Shift Super-
visor has written authority to direct maintenance without an accompanying MR
in an emergency.
In this case, the MR package is to be generated quickly
either before or immediately af ter completion of the maintenance work.
In summary, the inspector found that the MR format was comprehensive and that
approvals for commencement of work (Shif t Supervisor tagout approval), as well
as QAC review and Nuclear Plant Relic.biity Data System (NPRDS) review, were
adequately addressed.
(c) Equipment Maintenance Records
The inspector reviewed completed MRs and the equipment record (visi-card) file
associated with them. Completed MRs were filed in numeric order, which made
retrieval easy using the accompanying log.
For example, the inspector cross-
referenced MR 89-0724 (replacement of 8 RHR containment spray nozzles) with the
visi-card for the RHR system.
The appropriate work entry was found on the
visi-card to match the work performed.
Repair time is not routinely entered on
the visi-card, even though a space is provided for such an entry.
Vermont Yankee does not have a single Master Equipment List that meets the
generally accepted industry standard (i.e. , INPO) for such lists.
The licensee
has several discrete lists in use by different departments. Many of these lists
are called Master Equipment Lists by the user departments, and are referred to
as such in approved plant procedures. The maintenance department uses their
.
_u_ - - - - - - - _ , - - - - - - - - _ _ _ _ - - _ - - - - - - . - - - -
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' visi-record system as an equipment list; there is a plant Master Equipment List
for safety related equipment, and another Master Equipment List for Environmentally
Qualified (EQ) equipment as defined in the EQ manual. Although the inspectors
found no' obvious examples of confusion resulting in maintenance errors, the
existence of several " master" lists with the same title and different functions
- is confusing and is cause for concern. The licensee is considering the develop-
ment _of a computerized data base as their Master Equipment List. This would
standardize' the equipment listing and aid the maintenance process.
The licensee has a two-tiered root cause analysis program. On the larger,
system-wide level, the operating staff reviews each failure event to establish
.
its root cause. This analysis is intended to focus on the larger human issues
that can cause a failure. event.
For example, these issues could be procedure
content and clarity, training inadequacies, human factors, communications,
coordination between departments, etc. The Engineering Department, on the
other hand, reviews failure events at the component level. This review is
much more narrow and technical in scope. The inspectors reviewed the root
cause analysis memorandum prepared by the engineering staff and found it ade-
quate.
Topics included component design,. construction and application, main-
.tenance history,' testing required, service life, etc. The root cause analysis
program as implemented by the licensee appears to be a logical approach to the
subject.
. The final- step in maintenance request processing is consideration for Nuclear
- Plant Reliability Data System (NPRDS) applicability. The inspectors reviewed
- the licensee's NPRDS process and found it adequate. The licensee? s yearly
input of NPRDS reports of failure (Form NPRDS-4) is average for all utilities,
thus indicating that the licensee meets the industry norm for NPRDS participation.
' (d) Job Planning
The inspectors reviewed various aspects of job planning in use by the licensee.
Of particular note was evidence of appropriate technical manuals in use during
non-routine or unusual maintenance activities.
The inspectors noted that the
battery vendor's technical manual was in use at the testing location and the
diesel generator technical manual was on a clean bench at the front end of
the engine.
In the case of the camshaft replacement on the diesel generator,
the vendor manual parts drawing was used to order expected replacement parts.
As noted in Paragraph a) above for the diesel generator camshaft repair, improve-
ments can be made in this area so that parts expected to be used are available,
do not require special orders, and will thus not suddenly appear on the " critical
path."
Major work items have a walkdown review sheet (the walkdown review process is
documented in plant procedure VY-PWG), and when possible, the procedure to be
performed is walked through in its entirety. This process includes simulating
adjustments and ensuring that tooling, staging, shielding, etc., are appropriate
and available, and that the procedure is logical and can be performed as
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described. When it is not possible to walk through or simulate the work to be
performed (e.g., the work is in a high radiation area), experienced staff
members review the procedure package and provide their comments on the intended
_:
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plan.
Every attempt is made to make the walkdown process as complete and
accurate as possible in an attempt to make the actual maintenance go as quickly
and efficiently as possible.
(e) Work Scheduling
Maintenance scheduling during plant operation is coordinated by the operations
department.
Routing maintenance tasks are discussed, scheduled, and tracked by
maintenance department foremen and shift supervision in the control room.
Larger, non-routine maintenance tasks that niay stretch over several days or
weeks are subjects of discussion at the weekly plant staff meeting. These major
maintenance tasks thus receive the attention of operating, maintenance, and
plant supervision.
The maintenance scheduling system used during outages is, by necessity, more
sophisticated.
During each refueling outage, the operations planning group
assumes responsibility for tracking the myriad maintenance requests associated
with the outage. A computer program is used to arrange MRs both by the system
and by numerical order.
Tracking begins when the Shift Supervisor authorizes
work to begin.
Tracking ends when post-maintenance testing is satisfactorily
completed and a "close out" status entry is made to the tracking system computer
program.
The inspectors reviewed both scheduling systems (during operation and during
the outage) and found them adequate. The licensee stated they are considering
the use of the computer tracking system during operations as well as during
refueling outages because of the system's flexibility and accuracy.
(f) Post-Maintenance Testing
The inspectors reviewed several maintenance requests (MR) to determine the
extent and technical adequacy of post-maintenance testing (PMT). This review
found that PMTs performed were entered in Section D of the MRs reviewed.
Inter-
views with the maintenance and operations staff revealed that PMT requirements
may be invoked by either maintenance or operations as necessary, based on the
work accomplished.
For example, maintenance on safety related motor operated
valves is followed by the generic procedure associated with the maintenance
performed (e.g., valve leak testing or stroke timing). The process and cri-
teria of PMT are not prescribed in the Maintenance Request procedure (AP-0021),
which controls the maintenance activities.
Lack of a procedura11 zed PMT require-
ment is a weakness in the licensee's maintenance program.
(g) Review of Completed Work Control Documents
The inspector interviewed members of the maintenance staff and found that there
is no formal procedure that describes how completed work control documents are
reviewed.
However, work control documents are reviewed based on their complex-
ity.
For example, maintenance that is controlled by an MR only (routine tasks
well within the craftsmen's basic knowledge) receives a review by the appropri-
ate department head or assistant foreman.
This review is conducted to ensure
that the MR is complete, all data is taken and values are appropriate, the work
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effort is correct for the problem described, and that the MR pacAage is complete.
Maintenance items that require an accompanying procedure (surve'llance items,
for example) receive a review by an assistant foreman and another review by
the Maintenance Engineering staff.
These reviews are designed to ensure accur-
acy and completeness.
C_onclusion
The licensee has developed a functional work control program. Work is being
planned and scheduled in accordance with directives. The licensee's strength
appears to be in the professional attitude and attention to detail shown by the
staff. The staff and management appear to be "self starters", striving to
improve their plant's performance.
Indeed, the inspectors noted the pride in
load factor and availability data recently compiled by Vermont Yankee (1984
established a world record for reliability and 1988 was the plant's second best
operating year).
It was apparent that the staff and management appreciate the
role that judicious predictive, preventive, and corrective maintenance play in
overall plant performance.
The licensee does not have a procedurized requirement for their post-maintenance
testing nor an integrated Master Equipment List.
These are considered weaknesses
in their maintenance program. Areas where there is room for improvement generally
involve formalizing the actions now being taken.
Formalization (documentation
of a comprehensive approach to an activity) generally will enhance consistent
performance of tasks and provide a baseline for controlling and measuring trends
in future performance. The inspectors recognize that excessive documentation
can limit flexibility and timely response to plant conditions; however, given
the licensee's strong dependence on the current staff's skill and knowledge.
near term formalization of program requirements to set the stage for continued
good performance in the face of projected future staff turnover would appear to
be very prudent. The inspectors considered this one issue to be the licensee's
greatest liability in sustaining future good performance.
3.2 plant Maintenance Organization
Scope
The objective of this inspection was to determine the effectiveness and extent
of control exercised by the maintenance organization for:
(a) maintenance
activities, (b) contract maintenance personnel, (c) deficiency identification
and control, and (d) maintenance trending.
Findings
(a) Control of Plant Maintnance Activities
The inspectors observed work in progress in mechanical, electrical, and instru-
mentation and control (I&C) disciplines, and interviewed various staff members
_ _ _
_ - - - _ _ _ - - _ _ _ _ _ _ _ - _ - _ _ - _ _ - _ - _ _ _ - - - _ _ _ _ - _ - _ - - - _ .
_ -__-__ _
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performing the work. The team found that maintenance activities generally
follow the steps outlined in the Vermont Yankee maintenance procedures. All
.
work performed by Vermont Yankee or by contractor maintenance personnel is
closely monitored by Vermont Yankee supervisors.
Although Vermont Yankee does not have a general procedure which applies directly
to configuration control, the integrity of work performed on mechanical,
electrical and I&C systems is governed.by other procedural requirements con-
tained in a series of licensee documents. Furthermore, Vermont Yankee relies
heavily upon the expertise and knowledge of maintenance personnel and supervi-
sors for maintaining system and component integrity during repair work.
All materials used during maintenance are documented on the MR forms for
safety related repairs by indicating the number of the Material Issue slip from
the warehouse.
However, this documentation is not vigorously carried out and
the inspectors observed that one slip number often applies to several material
items (e.g., gaskets, rings, etc. were obtained from the warehouse for repairs
on multiple components). The inspectors also found that the licensee does not
have an effective policy for controlling and updating vendor manuals (See para-
graph 2.2 for more detail).
Vermont Yankee uses the " Peer QC" method to independently verify most activities
by which craftsmen and technicians not directly involved in the work being per-
formed monitor it to verify quality. The team found this method to be effective
for monitoring maintenance work.
Although the licensee has a satisfactory program for controlling maintenance
work performed by its staff and by contractor personnel, in many cases the
documentation for the work is informal and not included in official records.
This lack of formal documentation is a potential source of errors and is an
area that need to be improved.
,
For mechanical maintenance, the inspectors reviewed implementation of work
controls for the following activities:
Emergency Diesel Generator "A" overhaul
Feedwater/ Condensate Demineralized Filter Replacement
3A and 3B Feedwater Heaters Modifications and Repairs
a
Main Turbine-Generator Low Pressure Turbine "A" Rotor Replacement
Main Turbine CIV and 3 top Valves Inspection
Main Condenser Boot Replacement
The inspectors' review of maintenance documents used for these activities, in
combination with interviews of maintenance personnel, supervisors, and contrac-
tors, indicates that administrative and special work controls are being effec-
tively implemented. Maintenance personnel were knowledgeable about work con-
trols which applied to their activities and were able to demonstrate how specific
controls for which they had responsibility were being implemented. The inspec-
tors noted that mechanical maintenance personnel generally have the opportunity
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to exercise judgement on the methods and techniques for implementing work con-
trols at a level appropriate for a specific activity.
The inspectors observed
that the close involvement of supervisory and management personnel during main-
tenance work in progress provided additional assurance that work controls were
properly implemented and that contractor personnel were closely adhering to
maintenance program requirements. The inspectors also noted that the work
areas, tools, materials, and replacement parts were properly identified and
were consistent with specifications in maintenance work documents.
In the electrical maintenance areas, the inspectors observed maintenance work
being performed on the following components:
'
Limitorque operator on motor-operated valves (MR 88-2831)
Target Rock valves (MR 89-0273)
Breakers in 115k line (MR 88-2139), 4kV line (MR 88-2108)
and 480 VAC line (MR 88-2068)
Bus bar in 4kV line
Overcurrent relays
Main station battery
The maintenance on these components was performed in most cases by contractor
personnel and supervised by the Vermont Yankee staff.
The inspectors observed
the work as it progressed and talked to the craftsmen and their supervisors.
The inspectors found that the work was performed in a highly competent way.
The technicians were well trained, experienced, and. motivated.
For example,
the maintenance of limitorque valve operators was performed by personnel from
MOVATS Company, which specializes in this type of maintenance work. Repairs of
cracked insulation on the 4KV bus bar were performed by personnel from General
Electric Company, the original designer of this component.
In the I&C maintenance area the inspectors observed on going maintenance activi-
ties on the Control Rod Drive System and the Scram Discharge Volume instruments-
tion. _The work involved replacement of diaphragms in scram valve actuators
and replacement of the existing RIS power supply with a "Technipower" power
supply. The inspector found that the technicians were knowledgeable about the
requirements and the work, had controlled and calibrated measuring tools and
equipment, and were performing the work according to the procedure specified.
The wiring connecting the power supply was properly terminated and trained.
The inspectors noticed, however, that the MR for the Control Rod Drive System
specified a quality control inspection of two valves at the beginning of each
s'ift, although there were no QC personnel present and no indication that any
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quality control inspection took place at the beginning of the shift.
In response
to the inspector's concern, the licensee representatives from the maintenance
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department indicated that in their opinion a shift refers to the total period
of time it took to finish the job, which could be in some cases several days,
,
weeks, or months. The inspector pointed out to the licensee that a shift has
'
been formally defined and approved by plant management in the Outage Manual as
I
lasting 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. This issue was brought to the maintenance superintendent for
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resolution. He explained that this was due to incorrect use of the word
" shift in the MR.
It was always their intent to perform under this MR quality
control. inspections of a total of six valves during the outage, two valves from
each of the three shift-crews. He stated that'the MR would be revised to avoid
the confusion.
The inspectors found that, in general, the maintenance activities in mechanical,
electrical, and I&C areas were being performed in an efficient and professional
manner.
(b) Control Of Contracted Maintenance
.
A large portion of, the maintenance work at the Vermont Yankee plant is performed
by contractor personnel, especially during refueling outages.
In some cases,
the contractor personnel work directly under supervision of Vermont Yankee staff.
At other times, especially for some larger maintenance jobs that are subcon-
tracted to outside organizations, these firms then provide their own super-
vision, very often follow their own procedures, which have been reviewed and
approved by Vermont Yankee PORC, and may have their own QA program which has
'
been. approved by Vermont Yankee QA. However, regardless of the contractor's
programs, the Vermont Yankee staff always monitors the progress of the work and
maintains final approval.
Contractor personnel are selected first by reviewing their resumes and then by
interviewing potential candidates before selection is made All those not
employed by Vermont Yankee for longer than a year undergo a background check by
'the plant security, with special attention paid to drug and alcohol use.
Selected candidates undergo training, described in procedure AP 0700, which
consists of General Employee Training (GET), including familiarization with the
general plant rules and regulations. This training must be taken by all new
employees. Then each employee receives specialized training in the area of his
or her expertise. This training may be performed in different departments, but
t
it is always coordinated by the Vermont Yankee Training Department. The
training may consist of classroom lectures and/or on-the-job practical training.
In many cases the training includes working on mockups of actual plant equipment
i
to allow employees to gain needed experience before they start working on
actual equipment which may be located in radiation areas.
1
The inspectors reviewed the training program and interviewed the training
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coordinator. The program seems well planned and able to provide comprehensive
training in the areas of interest to the maintenance organization.
It is flexible
and continually modified and updated to meet the needs of the plant. The team
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was especially impressed by the great attention paid to practical training. As
1
an example, Vermont Yankee purchased an expensive circuit breaker for the sole
I
purpose of using it as a training tool.
All work performed by contractors is controlled by the Vermont Yankee mainte-
nance staff through a maintenance request system.
Contractor work is verified
I
and approved by appropriate VY staff members. The VY maintenance organization
is responsible for providing contractors with up-to-date procedures and vendor
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manuals and an existing program controls a release of the procedures to working
parties. . -There is also a process by which these procedures are continuously
updated.
1
The review and updating of vendor manuals is done by the maintenance supervisory
L
. staff, but the' process is very informal and not particularly efficient (See
L
section 2.2 for additional detail regarding vendor manual control).
Before
'
starting a maintenance job, the responsible supervisor assures that all the
. people assigned to the job have proper training.
If training is needed, the
supervisor's responsibility is to inform the Training Department in advance so-
,
that proper training can be provided.
L
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(c) ' Deficiency Identification and Control
'
The inspectors revt'ewed the licensee's maintenance organization's equipment
deficiency identification and control and interviewed plant management and
supervisory personnel. The inspectors determined that the licensee has a well
established program _ for identifying equipment deficiencies in the plant.
Each
deficiency identified could fall into.one of three categories and result in
the:1ssuance of a Maintenance Request (MR), a Non-Conformance Report, or a
Potential Reportable Occurrence Report. The licensee then takes appropriate
action which is determined by a suitable procedure. The inspectors also
learned the details on how the different elements of the organization interact
and how rigorously actual maintenance work follows the path determined by the-
-written procedures.
Based on their review of maintenance procedures and interviews,
the inspectors determined that in general the present program of deficiency
identification and' control provides a means for conducting successful mainte-
nance operations in the Vermont Yankee plant.
(d) Maintenance Trending
-The maintenance organization has a program for the systematic trending of equip-
ment and system failures. The purpose of this program is to evaluate the need
for increased maintenance activities to identify the need for common failure
mode analysis and to' determine gradual trends in equipment failure rates. When
the program was instituted in 1985, failure data from 11 previous years were
analysed and the average and control failure rates (two standard deviations)
were determined.
Presectly the program includes trending of failures for 24
components and systems and already provides useful information for planning
preventive maintenance on Uninterruptible Power Supply (UpS) and other compo-
nents. There is an ongoing effort to extend this program to include the root
cause of failures. Trending this parameter would provide much more useful
' data than trending equipment failures, because it would eventually permit a
I
suitable analysis to determine common cause failures. ' Expansion of this part
of the program is, however, still in its preliminary stage.
Specifications in the procedure for preparing trending data requires that the
,
assigned maintenance engineering personnel record failures of equipment and the
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probable cause from the information on Maintenance Request Forms. These data
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are then plotted on trending charts and analysed for the root cause of the fail-
- ure. Presently.there is backlog of data on which this analysis has to be per-
formed. The engineer in charge told the inspectors that in the future they
,
intend to put more resources in' this area to reduce the backlog.
Once this
program is' fully implemented it should produce useful results which will help
to enhance the plant's maintenance program.
Conclusions
The inspectors concluded.that the maintenance organization had a well developed
program for performing corrective and preventive maintenance. The main strength
of the organization lies in its highly trained and competent staff.
Careful
selection and an effective training program assured that contractor personnel
were we11' qualified for performing their jobs appropriately. The contracted
work is supervised and monitored in a satisfactory manner.
The failure trending
program under development is well cor.ceived and will probably contribute signifi-
cantly to.the improvement of the predictive maintenance program.
The inspectors
found Vermont Yankee to have a well' functioning maintenance organization.
3.3 Maintenance Facilities,- Equipment, and Material Controls
Scope
The objective of this inspection was to assess the plant's maintenance facilities
and controls over maintenance equipment, tools, and materials to determine how
well these' activities support maintenance work.
The following areas were
evaluated during this inspection:
(a) Provision of maintenance facility and equipment
(b) Establishment of material controls
(c) Establishment of maintenance tool'and equiprent controls
(d) . Control and calibration of metcr and test equipment
Findings
(a) Provision of Maintenance Facility and Equipment
The inspectors conducted an extensive tour of maintenance facilities to assess
the extent to which facility arrangement, layout, and accessibility are conducive
to efficient maintenance operations. The inspectors noted that the locations of
mechanical workBops, the machine shop, fabrication shop, main storehouse, tool
room, and temporary repair shops are physically adjoined to and clustered around
the reactor and turbine buildings in such a manner that ready access to these
,
facilities is afforded from all areas inside the plant.
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Maintenance facilities are located to provide controlled access from the out-
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doors for passage of personnel and material without requiring that they enter
through the plant. The flow of personnel and material throughout the plant is
well accommodated by efficient traffic patterns and locations of entrance and
exit points to maintenance facilities. The I&C equipment storage and testing
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shops are located directly adjacent to the control room, switchgear rooms, and
cable spreading room for ready access-to those areas. The machine shop, tool
room, and storehouse are located in close proximity to each other and afford
efficient access to these areas. Supervisor's offices are located directly
adjacent to and within sight of maintenance shop facilities. Maintenance and
I&C Engineering offices are also located adjacent to their respective shops;
however, they are not within direct view and were afforded some separation from
normal plant traffic. The Maintenance Superintendent's and Plant Manager's
offices, located in the administration building, provided ready access to main-
tenance facilities but were adequately separated from the plant with regard to
I
their administrative duties.
Support organizations, such as Health Physics,
Safety, and Fire Protection, also share facilities immediately adjacent to the
i
plant and generally do not need to have direct access to the maintenance shops,
l-
although direct access to the plant is afforded.
The inspectors walked throughout the reactor and turbine buildings to observe-
the temporary maintenance areas established to provide local support for spe-
cific maintenance and modifications projects (e.g., turbine rotor replace-
ment, feedwater heater modifications and repairs, plant pipe lagging, and re-
placement). The inspectors noted that the ample space allocated to all in plant
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maintenance areas permitted efficient work and avoided congestion.
Staging and
laydown areas were well organized and controlled to provide sufficient temporary
storage and efficient material utilization, component layup space, and personnel
traffic routes. Scaffolding for all plant areas during the outage was provided
by a single contractor and was arranged and constructed in a way to afford the
efficient passage of personnel and materials around affected areas. More than
a sufficient quantity of, scaffolding was provided for the necessary maintenance
work and it was arranged to provide direct and safe access to work areas.
Scaffolding was well protected against personnel hazards and was often utilized
to provide temporary support for service lines or other temporary equipment
which could create a safety hazard at floor level.
The inspectors observed that communications systems were installed in all areas
throughout the entire site. The "Gaitronics" four-channel phone pager system
was heavily utilized by maintenance personnel for short conversations. An
independent sound power phone network was also installed for supporting specific
maintenance and testing work. These systems provided more than adequate
communication service for maintenance work in progress.
(b) Establishment of Material Controls
For Material Controls review, the inspectors reviewed the adequacy of adminis-
trative policies and procedures for implementing effective control of materials
(components, spare parts, consumables, etc.) used in maintenance, beginning
with material requisition and extending throughout material installation or use.
The inspectors observed that adequate guidelines have been established for iden-
tifying and assigning necessary material specifications, by site-based " user
departments," for use 'n maintenance applications. Adequate controls have been
implemented for identifying safety-related materials and for specifying the
necessary special controls over the procurement of safety-class material. The
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" Safety Classification Manual" provides the necessary instructions to site
groups who initiate material requisitions.
The inspectors observed the process
of. initial material requisition, through the corporate purchasing function, QA
review, purchase approval, and final ordering. These procedures were adequately
controlled and sufficiently well established to ensure that in most. cases
material requisitioned for maintenance activities are processed far enough in
advance of use to be available in sufficient quantity for their intended
purposes. No maintenance activities were observed to be delayed due to late
requisition processing or purchasing.
, .
The inspectors noted that adequate guidelines have been developed for ensuring
that. proper material certificates are provided with material that arrives on
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^ packages maintained on safety class items in receipt inspections. All packages
'
The inspectors reviewed documentation of individual material history
site.
reviewed contained complete information and certifications to support material
identification through objective evidence obtained from approved suppliers.
The approved suppliers' list was also reviewed by the inspectors and a discussion
was held with the licensee's vendor audit group regarding the vendor audit pro-
gram. The inspectors reviewed several recent vendor audit reports conducted on
several " approved vendors" currently providing contractor services during the
outage. No unsatisfactory conditions were noted.
The inspectors reviewed the computerized data base used for tracking the entire
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site storehouse inventory. Minimum and maximum stocking levels are identified,
as is current inventory on hand. Automatic reordering is initiated when inventory
drops below minimum levels.
The inspectors noted that all material designated
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for a specific application may not necessarily be entered into the storehouse
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inventory listing but may be temporarily stored in the storehouse. Observations
of controls on the issuance of all material out of the storehouse indicate that
inventoried material is released only after certifications are made which
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associate specific work orders with specific material purchase orders.
The inspectors examined the site storehouse stock areas to evaluate the adequacy
of this-facility in supporting the maintenance effort. This facility provides
good physical security for all store materials and provides a " Category B"
storage environment for plant spare parts and consumable material. The inspec-
tors observed the areas designed for flammable and explosive materials storage
and determined that adequate controls were in effect to keep these materials
segregated from normal stock. The inspectors noted that no positive controls
are implemented in the storage areas to maintain " qualified" material physically
separate from "non qualified" material.
This does not appear to adversely
)
affect support to the overall maintenance effort since " qualified" material is
!
adequately marked and physically identified by tagging. All material
is identified by safety class in work packages and procurement documents which
are verified to be consistent before any material is released from the storehouse.
Non-conforming material is well segregated in the areas designated exclusively
for receipt inspection.
The inspectors observed these areas to ensure that
receipt inspection QC requirements were adequately implemented and that docu-
mentation of material history was maintained in a manner which provides complete
traceability. The inspectors reviewed the methods for upgrading and/or
_ -
_ _ _ _ _ - - _ _ _ _ _ _ _ - _
_ - _ _ _ _ _ _ - _
_ - - _ _ _ _ _ _ .
. _ _
__ _____.
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dedicating material presently'in the storehouse to 'a higher safety classifica-
-tion than was' originally designated by the purchase order. The upgrade process
can also be used to extend the shelf life of storehouse material where suffi-
,
l
cient technical justification can be shown. The inspectors reviewed selected
material upgrade and dedication evaluation (MAUDE) packages extending from
,
l
1987-89 and found no unsatisfactory conditions.
(c) Establishment of Maintenance' Tool and Equipment Control
l:
In the areas of Maintenance Tool and Equipment Control the inspectors toured
plant' areas to observe tools and equipment in use for various maintenance
i>.
. activities. Work documents in use for the emergency diesel generator overhaul
'
and the Hydraulic Control Unit (HCU) scram valves and actuators repair were
checked to. ensure.that the tools and equipment specified by the procedures were
in use. The inspectors also verified that finished work was properly documented
so that exact tool usage could be retraced at a later time if necessary. Tools
and equipment were noted to be clearly identified and serial numbers agreed
with the tool room sign-out logs.
In one instance, the inspectors noted that a
torque' wrench (VY #3906) in use on the diesel generator had a calibration label
attached which indicated a valid calibration period in excess of the 18 months
allowed by Administrative Procedure AP-0201. The inspectors discussed this
concern with the Maintenance Engineering Assistant. The Maintenance Department
QC records.were checked to confirm that the actual allowable period for the
wrench was in fact 18 months and that the wrench had been mislabelled.. The
wrench was more than 12 months from the actual required recalibration date and
' the engineering assistant indicated that the wrench would have been removed
from service slightly earlier than the due date through normal administrative
controls.
d)
Control and Calibration of Meter and Test Equipment
The inspectors reviewed the " Vermont Yankee Calibrated Tools & Instruments"
list for Maintenance Department Meter and Test Equipment (M&TE) to compare
equipment specifications with the actual equipment identified on the list.
The inspectors toured the tool room areas where Maintenance Department M&TE are
calibrated and stored.
Storage lockers were noted to be well organized and
suitable for protection of calibrated equipment. The inspectors examined the
torque wrench bench tester (Snap-On TQTP650), reviewed the procedure for torque
wrench calibration with the tool room custodian, and verified that records of
certification were maintained for bench test users. No inconsistencies were
found. However, the inspectors identified three documentation problems as-
sociated with calibration of tools as follows:
(1) Three "Hytorc" wrenches
designated on the list as being out of service for calibration did not have
supporting documentation on M&TE sign-out sheets (VYAPF 0201.01) maintained in
the tool room. Section 6.8 of procedure AP 0201 requires any tools removed
from the tool area be logged by the tool attendant on VYAPF 0201.03.
(2) A
-further review of tool room documentation revealed that two outdated Torque
- - - _ - _ _ _ _
__ _ __ - _-______
_____ _ _ _ ___
_
_ -
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34
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Wrench . Calibration Data Sheets (VYAPF 0201.03) had been used to record data
obtained during a recent calibration of a torque wrench (VY #5115). Adminis-
trative Procedure AP-6805 requires that old procedure data sheets and forms be-
destroyed when a new revision to the applicable plant procedure is issued.
(3) The inspectors noted that procedure AP-0201 requires all torque wrenches
to be clearly labelled with "CW" and/or "CCW" to indicate which direction the
wrench is calibrated,
i.e., clockwise or counter clockwise, respectively. No
torque wrench in the tool room, and none observed in use in the plant, had the
labelling indicating the direction of calibration. These findings constitute a
violation of 10 CFR 50 Appendix B, Criterion V (50-271/89-80-04).
.
Conclusion
.The inspectors concluded that maintenance facilities are well arranged,
equipped, and maintained in a manner which supports the efficient conduct of
maintenance act'eities at Vermont Yankee.
Facility layout and space utilization
for maintenance work were well planned, organized, and controlled. The flow of
personnel, material, and equipment throughout the plant complex was well
accommodated by maintenance facilities.
In the area of material control, the iraspectors concluded that existing administra-
tive policies and procedures provide adequate controls for specifying, procuring,
receipt inspecting, and storing materials utilized for maintenance work. Safety-
related materials are adequately identified and controlled to ensure that such
material is properly procured, stored, and issued for the intended use.
The
material tracking systems in use in the storehouse is adequate for maintaining
minimum stock levels and for properly accounting for all material received,
stored, and issued from the storehouse. The procurement program.was observed
to be well administered and implemented to ensure that materials used for main-
tenance activities are properly specified, obtained, and received in a timely
manner which supports maintenance work schedules.
In the area of tool and equipment control, inspectors concluded that tool and
equipment identification, storage, and use were adequately controlled in main-
tenance work.
Management's attention is needed to resolve:
(3) the documentation problems
associated with the calibration of tools, and (2) torque wrench calibration
labels not in accordance with the procedure.
I
i
_ _ _ _ . _ _ _ _ _ _ . _ _ _ _ . - _ _ - _ _ . _ _ . _ . _ . _ _
..iJ
q
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'
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35
3.4 Personnel Control
Scope
'The. objective of the inspection in this area was to determine the extent to
which personnel are trained and qualified to perform maintenance activities.
'In assessing this topic, the inspectors examined the following four areas:
staffing control, training, testing and qualification, and current status. The
inspectors' evaluation was based on interviews, direct observations of the
training facility and field activities, and reviews of documents and records.
4
Findings
Staffing control was assessed mainly through interviews with maintenance super-
visors. The team found.that organizational charts were complete and up-to-date.
The personnel turnover rate is low (less than one percent per year), .resulting
in a highly experienced staff with typically 8 to 15 years of onsite experience.
The inspectors reviewed the licensee's training and qualification program in-
four areas: (1) Radiation Protection / Chemistry; (2) Mechanical / Electrical Main-
tenance; (3) Instrumentation and Controls; and (4) Technical Staff / Manager.
The-training and qualification program in these four areas is INP0 credited.
Supervisor / Management training is also provided on an as-needed basis.
Diagnostic testing is used to help identify individual weaknesses where
additional training' may be required.
A formal training, qualification, and certification program does not exist for
contractor maintenance personnel.
However, in addition to the required indoc-
trination training, contractor personnel receive speciality training as necessary
for specific jobs. Close on-the-job monitoring and supervision are the primary
methods used to assure the appropriate level of contractor performance.
Speciality training provided to contractor and licensee personnel for the outage
included: scram discharge valve replacement (a mockup valve was purchased for
'this training), circuit breaker maintenance, squib valve maintenance, and valve
maintenance using various valve cutaways. In addition General Electric provided
onsite mockup training to support primary recirculation pump maintenance.
An assessment was performed of the licensee's current status of the fitness for
duty program and of work performed by unqualified personnel. Drug screening is
performed upon initial employment and subsequently as justified by probable
cause.
State law prohibits the implementation of random drug testing.
Conclusion
Based upon interviews with maintenance supervisors and training personnel,
observations of maintenance personnel performing various activities in the
field, and reviews of the qualifications of the individuals performing the
l
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_ __
.
-
_
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_ _ _ _ _ _ _ _ _ _ _ _ _
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_ _ _ .
.-_-_ _ - ___ _ - __
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36
- ' ..
work, the inspectors determined that the licensee has a comprehensive and well-
planned training prt> gram for their maintenance personnel and that the licensee's
personnel control program is adequately documented and implemented.
Based on
the result of interviews with the Medical Services Director and maintenance
supervisors, as well as a review of the fitness-for-duty program, the inspectors
determined that the licensee has an adequate drug program to ensure worker's
.
I
. _ - . _ _ _ . . . _ . . - - _ - - . _ _ _ - - _ . . - - - . - - - . - - . - - - - - -
_ __
_ - - _ _ _ _ - - _ _
_
_
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.
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APPENDIX 1
Appendix 1 is a copy of the attachment to
the December 27, 1988 letter to the licensee
requesting site specific information.
PRE-INSPECTION REQUESTED INFORMATION
To aid us in preparing for the maintenance inspection please provide us with
the following documents, procedures and information in accordance with the
designated numbers. If you do not have the requested document or information,
.
it.is not necessary to generate it to comply with this request. We recognize
'that many of.the documents requested separately may be inclusive in a larger
single document.
Please provide five sets of the requested documents. A
member of our staff will contact you regarding the best method of transmitting
the documents to us.
Section 1 - Description of General Plant Maintenance Activities
1-1
Maintenance administrative procedures which describe your corrective,
preventive and predictive maintenance activities.
1-2
Organization charts including the maintenance organization and plant-
wide organizations.
~1-3
Procedures, charts and other documents which describe your Planning
Department and its activities.
1-4
Documents which describe maintenance planning and scheduling
meetings and status of maintenance reports.
1-5
Documents which describe the Maintenance and Operations interface
during planning, scheduling, work start, work closeout and post
maintenance / functional testing.
1-6
Documents which describe your work control process: how a work
order'is started, planned, executed, closed out and equipment
returned to service.
1-7
Documents which describe training and retraining of plant and
contractor maintenance personnel.
(For maintenance activities only,
do not include GET.)
1-8
Documents which describe interfaces and communications among the
technical support, engineering support and the maintenance /I&C
Departments.
1-9
Documents which describe maintenance work procedure establishment
and control: Criteria as to when a procedure is to be used; initial
writeup; reviews and approval; revisions; human factors review; QA
reviews; requirements for conduct of work; troubleshooting criteria;
work closecut; post maintenance testing and restoration of systems.
_
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1-10
Description of methods by which maintenance performance is measured.
Are performance indicators used? What are they? 'Who is informed
of the results?
1-11:
Description of process for communications with vendors for technical
services and latest technical information on equipment and systems
installed at the plant, and interfaces with vendors ~of NSSS for-
4
training, modifications and equipment replacement.
1-12
Documents which describe the preventive maintenance and predictive
maintenance programs.
.
- .Which equipment is included?
How is maintenance frequency determined?
s
What is done with results of these maintenance actions?
1-13-
Documents which describe management involvement in maintenance.
Are there goals- set for the maintenance and I&C Departments?
Are these goals used in the performance evaluation of managers
and supervisors?
Are these goals communicated to first hne supervisors and chiefs?
Section 2 - Status of Plant and contractor Personnel Who Perform Maintenance.
2-l'
The number of craft personnel for electrical, mechanical and I&C
maintenance organizations,
please include foremen and foreman to
craft' ratio.
2-2
The average years of experience for each individual and the
turnover rate.
2-3
Description of shift work and work assignments. How do foremen
decide on which' craft is to perform what type of work?
Section 3 - Status of Plant Equipment and Plant Maintenance
3-1
What equipment failures occurred during the last year of operations?
3-2
What equipment failures have been found during shutdown of plant?
3-3
Describe maintenance and testing for diesel generators and electrical
equipment including switchgear that would be required in case of
3-4
What component failures present greatest risk from a probabilistic
risk standpoint to the plant?
_ _ - - - _
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3-5
What have.been.the areas of-high maintenance activity on safety.
i
related and-non-safety.related equipment and components?
,
3-6
Provide the following status concerning Maintenance. Work Orders (MW0).
f
.:
- ' Current total listing and status of'MW0s, number in planning,
a
number in final sign-off, number on hold for lack'of parts,
number on hold for engineering assistance, number available to
be worked on.
- l Projected number of corrective MW0s to be outstanding at
!
start-up by priority.
.
3
- : Rate of completion of corrective MWO in terms of number
i
completed / month and manhours expended (by craft)/ month for the
_
past 12 months.
. Current number of preventive maintenance. work orders overdue.
Rate-of completion of preventive MWO for the past 12 months.
.
Estimated manhours required to complete current preventive
.i
maintenance MW0s.
_ Number MW0s requiring rework over past' 6 months.
3-7
Provide five corrective maintenance procedures for work that is
scheduled for the upcoming outage. MOVs, PRVs, ECS Pumps,
!
Batteries,-Switchgear, etc.
3-8
Provide five preventive maintenance procedures that are scheduled
for the upcoming outage.
3-9
Provide your overall outage schedule.
,
]
-
_ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . . . _ _ .
_ . _ . . . . . . _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ __
_ _ _ _ _ _ _ _ _ _
__.__._.__________.__.____________._____._________m
. _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ . . _ . _
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APPENDIX 2
PERSONS CONTACTED
j
. Vermont Yankee Nuclear Power Corporation
-
H. Atkins,' Assistant Maintenance Foreman
!
- D. Bauer, Assistant to Vice President
o
F. Burger,. Receipt Inspection Supervisor
!
- P. Donnelly, Maintenance Superintendent
G. Gilmore, Storeroom Supervisor
J
D. Girroir, Senior Quality Assurance Engineer
J. Golonka, Maintenance Technician ~
,
- S. Jefferson,-Assistant to Plant Manager
.
- R. Leach, Radiation Protection Supervisor
i
D. Legere, Senior Maintenance Engineer
- -R.-Lopriore, Maintenance Supervisor.
- J. McCathy, ALARA Engineer
- D. McElwee, Engineering Program Manager
i
- H. Metell, Engineering Support Supervisor
1
- W. Murphy, Vice President / Manager of Operation
- R. Pagodin, Technical Service Superintendent
j
- J. Pelletier, Plant Manager
'
- R. Spinney, Training Manager
- D. Stafford, I&C Training Coordinator
D. Taylor, Maintenance Engineer
'
J. Turner, Lead Electrician
i
- ~G. Wilder, Maintenance Training Coordinator
- R. Wanczyk, Operation Superintendent
- T. Watson, I&C Supervisor
. W. Wittmer, Construction Superintendent
Yankee Atomic' Electric Company
i
J. Culchera, Engineer
- R. Grippardi, Quality Assurance Supervisor
- J. Thayer, Vermont Yankee Project Engineering Manager
!
S. White, Senior Engineer, Vendor QA Group
Vermont Department of Public Service
i
- R. Sedano, Chief Engineer
- * W. Sherman, Nuclear Engineer
United States Nuclear Regulatory Commission
i G. Grant, Senior Resident Inspector
- J. MacDonald, Resident Inspector
- Denotes those present at the exit meeting at the Vermont Yankee site on
March 10, 1989.
-
_ _
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_.
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I
APPENDIX 3
SUMMARY OF WEAKNESSES
Weakness - A potential problem or condition presented for
Reference to
licensee evaluation and corrective action as applicable.
Report Section
1.
Lack of comprehensive and formally documented
2.2 & 3.1
maintenance plan and policies.
2.
Lack of comprehensive and structured review for
2.2
adequacy and applicability of the plant's
maintenance requirements.
3.
Review for the appropriateness and technical adequacy
2.2
of completed maintenance activities were not being
performed in a timely manner.
4.
Lack of effective policy and procedures for controlling
2.2
and updating manufacturer technical manuals.
5.
PRA concept not incorporated into Vermont Yankee
2.3.3
maintenance program.
6.
No integrated Master Equipment List for Vermont
3.1
Yankee.
7.
Post-maintenance testing requirements were not
3.1
proceduralized in the administrative procedure.
1
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APPENDIX 4
SUMMARY OF UNRESOLVED ITEMS
Unresolved items are matters about which more information is required in order
to determine whether they are acceptable items or violations. Unresolved
items identified during this inspection are listed below:
Reference to
Unresolved Items
Report Section
50-271/89-80-01
Potential for Drywell paint peeling to
2.3.2
clog the ECCS pump suction screen
50-271/89-80-02
Radiation exposure control above the
2.3.5
biological shield during fuel movement
50-271/89-80-03
Administrative control of " tag-out" as
2.3.5
it applies to an additional work party
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