ML20246Q297
| ML20246Q297 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, 05000000, Crane |
| Issue date: | 05/15/1989 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| FRN-53FR47822, RULE-PR-50 53FR47822-00088, 53FR47822-88, NUDOCS 8905220438 | |
| Download: ML20246Q297 (10) | |
Text
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GPU Nuclear Corporation N elear
'89 MAY 15 A8:19
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1 The Honorable Lando W. Zech, Jr.
Chairman U. S. Nuclear Regulatory Commission Washington, D.C.
20555 1
Dear Chairman Zech:
By letter dated February 24, 1989, GPU Nuclear Corporation (GPUN) submitted comments on the Notice of Proposed Rulemaking regarding maintenance'as published in the Federal Register dr ;ed November 28, 1988. We expressed our belief that a formal rule on maintenance is unnecessary and counter-productive to improving maintenance effectiveness.
1[believethatcurrentindustryinitiativesarefocused,significant,and resulting in improvements in plant safety and performance. Data available to the Commission clearly shows that these improvements are real. We believe these improvements are, to a large extent, directly attributable to better maintenance programs resulting from industry initiatives.
If the Commission concludes that programs or results at a particular plant are less than needed, existing Commission regulations and programs provide adequate basis for any appropriate action.
Such specific action would, I believe, provide better and more effective use of resources than the proposed rule.
We would like to take this opportunity, while the Commission and its staff consider final action on the proposed maintenance rule, to present to you and your colleagues additional information on maintenance program improvements undertaken and planned at GPUN nuclear facilities, specifically Three Mile Island I and Oyster Creek. The improvements discussed in the attachment to this letter are consistent with industry initiatives and reflect our commitment to effective maintenance.
8905220438 090515 3
53 47822 PDR 1
GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation
4 1.ando W. Zech, Jr.
Page 2 The attached information on GPUN maintenance activities and some performance indicators shows continuing improvements are being made and reflects our commitment to effective maintenance.
Our maintenance programs have and will continue to be developed with full consideration of safe and reliable operation. All this is a being achieved without the need for prescriptive regulations. Therefore, we urge the Commission to recognize that our efforts and those of the nuclear power industry have resulted in improvement.
Current programs and initiatives must be allowed to develop and demonstrate their worth.
The Commission's Policy Statement on Maintenance will foster the development of effective maintenance at nuclear power plants. A rule is not needed and would hamper our efforts by redirecting attention and resources.
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Sincerely, i
Philip R. Clark President c[: Commissioner Thomas M. Roberts Commissioner Kenneth M. Carr Commissioner Kenneth C. Rogers Commissioner James R. Curtis
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Attachment Gpu Nuclear Corporation i
Oyster Creek and Three Mile Island I f
Maintenance Improvements 1
OYSTER CREEK Maintenance activities are specified and prioritized by the Plant Materiel Department of the Oyster Creek Plant Division and are conducted by the Maintenance, Construction and Facilities (MCF) Division with support from other groups, e.g., operations, quality assurance, radiological controls, engineering, training, etc.
ORGANIZATION: Changes in organization have substantially improved capability and accountability.
The organization has been reduced to a maximum of four supervisory levels, thereby reducing direct reports and improving communication lines.
A split in maintenance from construction has resulted in higher visibility and greater concentrated efforts in each area.
A comprehensive Maintenance Plan was developed and issued based on INPO guidelines and a Maintenance Self-Assessment conducted.
STAFFING / INDUSTRY EXPERIENCE: Experience, training, and qualifications have been enhanced.
Industry information-sharing provides fresh approaches, good practices and early notification of potential problem areas.
Nuclear Mechanical Maintenance Technician - In January 1989, the new nuclear mechanical maintenance technician training started. The class is comprised of 11 trainees (7 new hires, 4 company employees). This new classification was developed during 1987 and 1988.
It will produce a cadre of highly trained equipment and systems-orientented technicians.
Eligibility requires an algebra and science background.
The initial training is made up of six months of plant systems and academic classroom work, followed by 12-18 months of on-the-job l
training (0JT) before reaching the full qualification level. This program will produce quality mechanical maintenance personnel and includes a rigorous biannual requalification requirement.
Technical support capability has been strengthened through addition of multi-disciplinary engineering personnel.
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1 PAGE 2 1
Staffing qualifications increased through utilization of an INP0-accredited Maintenance Training Program and the addition of a mechanical maintenance training lab. The lab has increased mechanics' classroom and OJT activity. Training is on schedule.
Speciality training has been increased from $34K in 1984 to $450K in 1988.
Qualifications for conducting enhanced safety reviews for the performance of maintenance / modifications have been improved by training on licensing basis, Tech Specs and FSAR required reading.
Examinations are also given.
Industry information systems (e.g. NOMIS, INPO NPRDS and CFAR) provide a useful resource on equipment problems and reliability at both Oyster Creek and TMI-1.
We are an active member of the BWR Owners Group Scram Frequency
. Reduction Committee. This committee conducts workshops in the instrumentation and control, mechanical and electrical areas to identify equipment problems, improve equipment reliability and enhance maintenance programs.
INFORMATION CORRECTNESS /USEFULNESS:
Efforts have been expended to address and improve this.
A concerted effort to examine drawing files (14,000 drawings) was implemented and resulted in 2100 drawings added to our controlled design data base, with 210 field annotations containing as-built -
information posted, and non-current drawings purged from the files.
A comprehensive review and upgrade of 250 technical procedures for maintenance including the addition of post-maintenance test (PMT) requirements was completed.
The maintenance administrative process has been enhanced by the implementation of GMS2, an on-line real time computerized system integral to job order creation, approval and closecut.
WORK CONTROL: Communications, responsiveness, efficiency and quality have improved.
Direct exchanges between Operations and MCF have been reinforced through daily Maintenance / Ops meetings whereby work sequence / priorities are established.
Both inter-divisional and professional interactions have been developed through supervisory attendance of the Corporate Training and J
Education Development program.
r PAGE 3 The GPUN vision, " Meeting the Energy Challenge with Leadership and Integrity", has and will continue to be shared with all employees.
Quality Deficiency Report responses have improved.
A 100% reduction in deficiency resolution response time through implementing tracking / expediting mechanisms has resulted. Corrective actions determined are precluding recurrence.
Quality of work has been evidenced through reduced rework and increased plant capacity factor.
Through reorganization and teamwork, better communications and work control have resulted. Maintenance efficiency, responsiveness to site needs, management-to-field communications, and work flow have also improved as a result.
Backlog has been dramatically reduced and is now at a manageable level with on-going efforts to further reduce.
Backlog prioritization by implementing the " system-out-of-service" concept has also had significant impact on backlog reductions.
Rework has been reduced through implementation of a stronger PMT program. The rework reduction effort has been controlled through the development and issuance of a " Control of Rework and Recurring Maintenance" procedure.
MATERIAL CONDITION IMPROVEMENT: Backlog reductions coupled with increased effort on preventive maintenance have improved overall plant material condition.
Plant material condition has been improved by a reduction in work backlog, from 1500 jobs (1/87) to 714 (2/89).
Backlog reduction has permitted us to focus on preventive versus corrective maintenance and enabled the organization to become increasingly proactive.
Control room instruments out-of-service dropped from 55 in June of 1987 to 30 in January of 1988 to 21 in January of 1989.
Temporary variations decreased from 121 in June of 1987 to 45 in January of 1988 to 21 in January of 1989.
Life of System Maintenance Plan - Utilizing reliability centered maintenance (RCM), we are developing formal plans to improve material condition, prescribe preventive maintenance and predict planned maintenance activities for the life of the plant.
Outcome of this effort will improve reliability of systems and componcnts while reducing challenges to operators (one system completed and under review; three components completed and under review).
RCM has been applied and maintenance plans for components such as reactor recirculation pumps, reactor recirculation pump motors, dilution pumps, etc., are being developed.
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I DAGE 4 A comprehensive Material Condition Study was conducted. - Based on the results, detailed action plans are being implemented. The end result of this effort will restore systems / components to a higher level of reliability while potentially reducing maintenance costs, reducing radiation exposure and/or placing maintenance into a more planned approach.
This effort also provides the corporate and site organizations a focal point for material condition issues such that corporate / contractor resources are effectively utilized to address maintenance of plant systems / components on a continuing basis.
Equipment Failure Trending Enhancements - Failure trends and analysis for both systems and components are being developed.
Based on the analysis of failure history and failure trends, planned maintenance activities can be prescribed as well as further root cause analysis of component failures. The results of these activities will revise preventive maintenance activities, prescribe predictive maintenance procedures, personnel qualifications, tools, etc., depending on the results of the analysis.
Machinery History Upgrades - Ongoing activities to improve machinery history are providing a better understanding of what is performed
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during maintenance. This assures that maintenance history can be utilized in the future to determine changes as necessary in maintenance needs.
A Predictive Maintenance Plan has been developed and is being implemented. Application of upgraded or new technologies into predictive maintenance will allow us to select appropriate times to conduct planned maintenance.
Current predictive maintenance activities include:
1)
Vibration Monitoring - Monitoring 640 points on 95 units of equipment at a monthly frequency and weekly, if required.
Results are trended and analyzed to prescribe planned maintenance activities.
2)
Lube Oil Program - Lube oil is sampled from 196 major components to determine condition of the oil and equipment life expectancy.
Ferrography inspection of the oil samples is a planned enhancement to the program.
PLANT PERFORMANCE:
Indicators show improvement is being achieved.
Dyster Creek had the second best operating cycle in the plant's l
history in 1987/88.
Oyster Creek had no safety system actuations in 1988.
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Oyster Creek had no scrams associated with maintenance activities in 1988.
Oyster Creek had no unplanned automatic scrams in 1988.
Oyster Creek had a reduced forced outage rate of 12.5% in 1988.
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THREE MILE ISLAND I The Plant Division specifies and conducts maintenance activities with resource support from the MCF Division and applicable support from other groups as at Oyster Creek.
ORGANIZATION / WORK CONTROL:
Changes have resulted in more effective maintenance activities.
The Plant Materiel Department was implemented in 1987 to focus additional engineering and experienced maintenance resources on programs to evaluate and improve plant material condition.
An expanded maintenance planning organization has been established that will improve cutage preparation and work package development.
The Plant Materiel Department includes an Assessment Group which has improved maintenance.
The Assessment Group provides Plant Materiel interface for numerous engineering projects.
STAFFING / INDUSTRY EXPERIENCE:
Enhanced personnel qualifications and industry feedback on maintenance-related issues have been beneficial.
Maintenance Training - A formal training program has been in place since 10-79, one week in training out of six. The Maintenance Training Program was fully accredited by INPO in 12/86. Maintenance training is considered one of the major factors for the plant's high availability.
We are an active member of the B&W Owners Group Availability Committee.
One of the projects worked on by this committee was the fuel handling bridge upgrade which included developing a comprehensive PM program.
Outage management and reliability centered maintenance were also addressed by this committee.
PAGE 6 We are also a member of the B&W Maintenance Working Group.
Some of the areas focused by this group were:
a.
assessment of repeat maintenance, b.
reactor coolant pu,?p and motor problems, c.
heat exchanger problems, and d.
operation and maintenance interface.
The Plant Materiel Assessment Group is the key organization in establishing communications between Plant Materiel departments at TMI-1 and Oyster Creek.
MATERIAL CONDITION IMPROVEMENT:
Programmatic upgrades and increased diagnostic capabilities have been implemented.
An effective PM Program has been in place since early 1979.
It is continually upgraded in order to increase the overall reliability of electrical, mechanical, and instrumentation equipment.
A quarterly assessment of PM program effectiveness has been in place since 1979. The PM program has recently been expanded to include common item failure analysis (common components across systems) and we have initiated an assessment of PM program effectiveness utilizing the 5 year assessment as a performance indicator.
A Root Cause Analysis procedure and process has been implemented. To date, we have completed root cause analysis on 11 problems.
Eight additional analyses are in progress.
Reliability Centered Maintenance - We have completed RCM evaluation of the plant feedwater system to the point of identifying proper maintenance tasks. We are presently implementing these RCM-derived tasks into the maintenance program on that system and performing RCM analysis on the condensate system.
We have reviewed and purchased new equipment to upgrade maintenance ability to detect and diagnose vibration-related problems and have incorporated the use of this equipment into the plant vibration programs.
A program to closely monitor reactor coolant pump (RCP) vibration and to evaluate data in order to detect problems such as a cracked RCP shaft has been initiated.
The use of more sophisticated mechanical alignment testing equipment has been incorporated into the plant's maintenance program in order to improve abilities in this area.
The motor-operated valve (MOV) program, procedures, and training were revised based on industry research results to improve MOV reliability.
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The use of full scale mockups has increased.
We have initiated action to obtain articulated arm tooling for RCP seal work.
The main steam safety valve maintenance procedure was improved based on INPO guidelines.
Desired improvements to RCP lubricating oil systems have been identified in order to reduce leakage and otherwise improve performance.
An initial inspection / identification of 140+ items related to Plant Life Extention and plant Condition Assessment has been performed. We are currently providing an initial evaluation and task assignment for action on individual items.
We have modified existing PM programs in areas of condition monitoring, lubrication program and check valve testing.
Program enhancements have been incorporated in areas of performance monitoring to more finely identify programmatic vs component unique problems. The result is a more aggressive approach.
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INFORMATION CORRECTNESS /USEFULNESS: SIMS (GMS2) implementation has had a positive impact at TMI-1.
SIMS enhances information collection by placing an on-line, real time main-frame computer as an integral and required element of maintenance job order creation, approval and closecut. The old system was adjunct to the maintenance administrative process.
SIMS enhances information quality and timely availability due to its requirements on component identification, the integral involvement of an engineering configuration control group, and the on-line availability of machinery history to supervisory personnel in all departments.
TMI-1 has installed an information center within its Plant Materiel Department containing data processing professionals with plant maintenance / operations backgrounds, and who ara dedicated to providing customized informational needs.
As the Assessment Group develops their statistical analysis methodology, this group wi'1 be an integral part of the process development.
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PAGE 8 PLANT PERFORMANCE: Good performance does not diminish our desire to do better and reflects effective maintenance programs.
TMI-1 had the world's fifth best operating record on the basis of capacity factor for the year ending March 1988, according to-the August 1988 issue of Nuclear Engineering International. The capacity factor for Unit 1 was 93 percent.
TMI-1 had an equivalent availability of 75.1% during 1988. This is-above the industry average, which is also steadily improving.
. TMI-1 had only one unplanned automatic scram in 1988.
TMI-1 had no unplanned automatic scrams due to maintenance activities in 1986-88.
TMI-1 had a low forced outage rate of 8.9% in 1988. Our goal for 1989 is 5% or less.
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