ML20247K657
| ML20247K657 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/30/1988 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20247K652 | List: |
| References | |
| PROC-880930, NUDOCS 8909210224 | |
| Download: ML20247K657 (75) | |
Text
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.. . y .1 NRC MAINTENANCE INSPECTION GUIDANCE VOLUME 1 i
SEPTEMBER 1988 4
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I NRC MAINTENANCE INSPECTION GUIDANCE VOLUME 1 1
Published September 1988 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4
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ABSTRACT
- This document establishes an inspection method for conducting performance based inspections of the plant maintenance process, activities and hardware, and for assessing the effectiveness of the licensee maintenance process based on safety significance. The results of these inspections will be used to assess the current status of the plant-specific maintenance process.
The inspection method 1) uses an analytical appraisal tree, in conjunction with plant inspections and performance observations, to identify systematic weaknesses and defects in a maintenance process, 2) provides a uniform inspection technique, and 3) establishes an overall evaluation of the maintenance process.
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- FOREWORD The Maintenance Process Inspection Program development was undertaken by f
the Nuclear Regulatory Commission (NRC) in February of 1988. The Inspection
- Program development was undertaken to provide a systematic method for determining the status of the' maintenance process throughout the nuclear industry. This report presents the inspection plan to be used during the l' inspection. The inspection plan was developed by the Office of Nuclear Reactor Regulation, Performance Evaluation Branch.
This report is contained in two volumes: the main guidance and the
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appendices. The main guidance provides the inspection guidance and criteria. The appendices contain the maintenance inspection checklists.
A number of the terms often used during the maintenance process are not completely understood. To reduce the confusion, these terms are defined in the Definition Section following the Table of Contents.
Numerous acronyms are used in this report. For each volume, these
-acronyms are defined in a listing following the listing of Definitions.
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CONTENTS MAINTENANCE INSPECTION GUIDANCE 11 AB S T RACT : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
iii FOREWORD ..............................................................
Vi DEFINITIONS ...........................................................
AC RON YMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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- 1. INTRODUCTION ......................................................
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- 2. INSPECTION METHODOLOGY ............................................
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- 3. SUMMATION OF THE FINDINGS .........................................
6 3.1 Program implementation.and Adequacy'.........................
8 3.2 Element Rating .............................. ...............
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- 4. INSPECTION CRITERIA ...........................................<...
Il 4.1- Overall Plant Performance Related to Maintenance (1) . . . . . . . .
11-4.1.1 Direct Measures (1.0) ...............................
13 4.2 Management Support of Maintenance (!!) ......................
13 4.2.1 Management Commitment and Involvement (2.0) ......... 16 l
4.2.2 Management Organization and Administration (3.0) .... 24 l
l' 4.2.3 Technical Support (4.0) .. ..........................
32' 4.3 Maintenance Implementation (111) ............................
33 4.3.1 Wo r k Cont rol ( 5. 0 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 4.3.2 Pl ant Maintenance Organization (6.0) . . . . . . . . . . . . . . . .
4.3.3 Maintenance Facilities, Equipment 53 and Materi al s Control (7.0) . . . . . . . . . . . . . . . . . . . . . . . . . 59 4.3.4 Personnel Control (8.0) .............................
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- TABLES 7
- 1. Element Rating System ..............................................
flGURES
- 1. Figure 1, Maintenance Inspection Tree (Working Tree) ..... Attachment 1
- 2. Figure 2, Rating Process Example ................................... 9
- 3. Figure 3, Maintenance Inspection Tree (Presentation Tree) .................................................... Attachment 2 v
DEFINITIONS AVAILABILITY A function of reliability and maintainability expressed as the probability that a system, when used under predetermined conditions, will operate satisfactorily at any point in time.
FORCED A forced outage, as defined in NUREG-0020, is an outage that OUTAGE is required to be initiated no later than the weekend following discovery of an off-normal condition. The forced outage hours are the clock hours that the unit is unavailable due to that initiating event.
MAINTAIN- A characteristic of design and installation expressed as the ABILITY probability that an item of equipment will be restored to specified conditions within a given period of time when maintenance action is performed in accordance with prescribed ;
procedures and resources.
l MAINTENANCE The aggregate of those functions required to preserve or restore safety, reliability, and availability of plant !
structures, systems, and components. Maintenance includes not only activities traditionally associated with identifying i and correcting actual or potential degraded conditions, i.e.,
repair, surveillance, diagnostic examinations, and preventive I measures but extends to all supporting functions for the conduct of such activities. ;
PREDICTIVE Techniques and activities employed to predict the onset of MAINTENANCE equipment malfunction or failure, e.g., vibration monitoring, acoustic monitoring, and oil analysis. ]
PREVENTIVE Regularly scheduled tasks (e.g., inspection, servicing, ;
MAINTENANCE adjustment, calibration, replacement) intended to keep .
equipment in condition for operational or emergency use.
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l' RELIABILITY- The probability that a system will perform a required function under specified conditions, without failure, for a specified period of time.
ROOT CAUSE An analysis performed to determine the cause of component or ANALYSIS part failures.
TRENDING An analysis of component or part history to determine ANALYSIS programmatic failure causes. Consideration should be given to part, component, system, and manufacturer.
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ACRONYMS AE: 0 - Analysis and Evaluation of Operational Data Branch of the NRC ..
.iLARA - -As low As Reasonably Achievable h S0P -
Balance of Plant 1
EPRI -
Electric Power Research Institute EQ
- Equipment Qualification ESF - Engineered Safety Feature L
FSAR - Final Safety Analysis Report GET - General Employee Training l- HP - Health Physics INP0 - Institute of Nuclear Power Operations ISI - Inservice Inspection l LER - Licensee Event' Report I NPRDS - Nuclear Plant Reliability Data System NSSS - Nuclear Steam Supply System l- NUMARC - Nuclear Management and Resources Council PRA -
Probabilistic Risk Assessment QA -
Quality Assurance QC - Quality Control RWP -
Radiation Work Permit SER. - Safety Evaluation Report TER - Technical Evaluation Report l
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MAINTENANCE INSPECTION GUIDANCE
- 1. INTRODUCTION The maintenance process inspection plan outlines how to conduct a i
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performance based inspection at a nuclear power plant and establishes a systematic means of determining the adequacy and effective implementation of the established maintenance process. The inspection plan divides the overall maintenance' process evaluation into three parts. Each part is rated _
for adequacy and implementation based primarily on performance observations and then assigned a rating. These evaluation ratings will be used to establish the overall rating of the maintenance process for the nuclear power plant. The three parts are 1) Overall Plant Performance,
- 2) Management Support of Maintenance, and 3) Maintenance Implementation.
The ratings for the three parts are determined from inspecting the following areas.
a)
Overall Plant Performance - Plant performance with respect to reliability of equipment, operab.ility and availability of equipment, and equipment maintainability.
b) Management Commitment and Involvement - The degree to which corporate and plant management is committed to and involved in the maintenance process determines the degree of effort assigned in establishing, implementing, and improving maintenance.
c) Management Organization and Administration - The adequacy of a maintenance program and its implementation is determined by proper organization and administration by management and its adininistrators.
d) Technical Support - An effective maintenance process requires adequate technical support.
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4 e) Maintenance Work Control - The procedures, work documents and administrative controls used in the implementation of the maintenance process determine ehether the maintenance process is effective and workable in a timely manner, f) Plant Maintenance Organization - The organization established for maintenance must adequately support the plant maintenance requirements.
g) Maintenance Facilities, Equipnent, and Material Controls -
Effective maintenance must be supported by adequate facilities, equipment to perform maintenance and proper materials control to assure required materials are used.
i i h) Personnel Control - Personnel staffing, training, and qualification are essential to properly support effective maintenance.
The maintenance process inspection, based on observation of plant l activities, will identify both strengths and weaknesses. The inspection relies upon a systematic critical analysis of observations, data, follow up of events, and upon the application of appropriate criteria for inspection of maintenance effectiveness and implementation. This objective is best achieved if the activity being evaluated has auditable measurements of performance. Lack of such informatica is often a strong indication of maintenance inadequacy.
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, ,. 2. INSPECTION METHODOLOGY The maintenance inspection methodology calls for two distinct efforts to j be performed as a part of the inspection process; inspection effort and j l evaluating the program adequccy. Each effort will be discussed separately.
l The inspection effort is to be performed by selecting a number of components or systems and inspecting maintenance activities associated with the selected items. The selection of components or systems is to be based on recent component failures, PRA insights, topics of interest, previous inspections findings, observations of plant activities, and event i actuancons. After the items of interest have been selected, the maintenance activities past and present should be reviewed. The review should include consideration for procedures (administrative, operation, maintenance, work order, technical support or specialized if applicable), following the appropriate procedures, records (training, work order, work history, calibration, etc.) evaluations performed, and any area determined to be pertinent.
Once the inspection is in progress, the second effort is conducted j simultaneously. This effort calls for evaluating each element of the -
inspection analytical tree for adequacy of documentation and ;
implementation. The evaluation is to be performed based on the inspection j observations and review. There will be cases during the inspection where an l element will not be inspected. In cases such as this, a decision needs to be made as to whether or not the element should be inroected separately.
When the decision is made to not inspect, the box would be colored blue.
The decision to inspect wsuld call for a directed inspection effort.
f The use and evaluation of the Maintenance Inspection Tree is a difficult I
l task that requires a team coordination and discussions. To assist in this task the analytical tree has been designed to be separated into parts for l analysis and report write-up purposes. The separation can be performed I
three ways. The first is that the tree 1's divided into sections using the l
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numeric style numbers (1.0, 2.0, 3.0 to 8.0) as the breaking point. Each section is assigned to an inspector. This method will meet the goal, however, the work load will be unbalanced in some areas. As an example, Section 6.0 (plant Maintenance Organization) requires one individual to become familiar with and ensure that the operations of all three maintenance organizations (IEC, Electrical, and Mechanical) are inspected. This individual would have an excessive amount of work. If this method is used, l it would be more appropriate to assign three inspectors (one for I&C, Electrical and Mechanical) to inspect Sections 5.0 (Work Control) and 6.0 (Plant Maintenance Organization). The inspectors could compare notes and develop a general consensus rating for each element. The remaining sections can be assigned to an inspector or multiple inspectors as is appropriate.
The second method is to sectionalize the tree and assign specific or multiple boxes to each inspector. This method meets the intent; however, the data could be collected piece meal if the element assignments are not made with care. Each element would be rated as the inspector determines.
The third method would be to assign an expert to inspect each of the organizations against the criteris applicable to that organization in the inspection tree. This method would meet the intent; however, it would be necessary to keep track of all of the areas inspected and ensure most of the tree is addressed.
It again should be noted that each element of the tree may not apply to the maintenance activities at each plant, could not be inspected, or enough data was not available to complete an evaluation. The team should exercise i professional judgment in eliminating or de-emphasizing elements that are not considered for a particular site. Elements that do not apply should be colored blue.
The inspection guidance is provided as guidance for use by inspectors in rating the effectiveness of the various activities and interfaces associated with the licensee's maintenance process. The inspector has latitude to use some or all of the attributes identified for the activity to characterize j 4
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its effectiveness in maintaining the selected components / systems so that they are available to perform their intended functions. However, the j guidance may contain practices based on "gcod engineering judgement" or I
" normal industry practice"; therefore, the guidance should not be construed as prescriptive requirements unless committed to in applicable licensing !
documents.
The maintenance inspection is to be a performance based inspection. An inspection focusing on selected components or systems to determine the effect on functional areas of the various elements of the licensee's j maintenance process is required. This focus on process effectiveness, I supplemented by limited programmatic reviews (including interviews of selected licensee personnel) will form the basis of this evaluation. The use of plant experience and PRA insights to focus the inspection is emphasized.
The maintenance inspection is intended to include the evaluation of the effectiveness of various plant and corporate groups in supporting the maintenance process as well as in evaluating the performance of the onsite electrical, mechanical, and instrument and control group. Through careful ;
selection of the system or components of primary focus, a performance based evaluation of these program activities can be accomplished. Additionally, this inspection is directed into areas for which explicit regulatory ;
requirements may not currently exist. Therefore, selection of components and/or systems derived from high risk event sequences and balance of plant ;
equipment may help to amplify the need for improvements in areas not traditionally classified as safety-related. ' An evaluation rating is then assigned to each applicable element. A detailed description of determining the adequacy, implementation, and rating is provided in Section 3. When each element has been rated, the overall rating of the maintenance process can be obtained as discussed in Section 3.2.
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- 3. SUMMATION OF THE FINDINGS A standardized method permits objective comparison of observations performed by different appraisers. The actual rating is accomplished by comparing the elements of the established and implemented maintenance activities with the criteria set forth for each eleu.ent of the analytical tree. The inspection criteria for each element are in Section 4.
The maintenance process inspection is to 1) identify the strengths and weaknesses of the maintenance process, and 2) establish a rating for each maintenance process area inspected.
3.1 Proaram Implementation and Adeauacy During the maintenance inspection process, the applicable areas of the maintenance process will be reviewed for adequacy and implementation. A color coding of each area is used to demonstrate the adequacy of the documentation supporting the specific area of the maintenance process and the adequacy of actual field implementation. The analytical tree is segmented into separate elements. Each element is separated into two parts diagonally. The area above the diagonal line is used to code how adequate the area of maintenance has been described and documented. The area below I the diagonal is used to code the degree to which the maintenance process element is implemented. The coding consists of shading the upper and lower areas of the element box in green, yellow, red or blue. When an element does not apply, was not inspected, or had insufficient data for evaluation, color the box blue. When indicating documentation adequacy, a green color code designates the element was observed to be fully included in the licensee's maintenance process; a yellow color code designates the element is being adequately addressed; and a red color code designates that the element is missing or inadequate. For the implementation, a green color code designates that the element is functioning and functioning adequately; a yellow color coding designates that the element is in place, but could be l strengthened; and a red color code designates that the element implementation is missing or inadequate.
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.= The color coding of each box can be green / green to red / red where green / green shows that that area of maintenance is well defined, documented, and implemented; and red / red shows that that area of maintenance if poorly defined, documented and implemented. The color coding can be any combination of green, yellow, and red. Combination colors of red-red or red-yellow would suggest weak areas (one more significant than the other);
yellow-yellow average, and green-yellow suggesting areas of strength.
The color coding of Section I of the inspection tree is handled independent of the romainder of the tree. This section deals with historic data and idant appes.ances. Due to the definition of these two elements, a two part breakdown is not appropriate. Each element is reviewed separately and each block is to be one color. When color coding Section I, a green represents the element as functioning well; yellow the element is functioning adequately; and red functioning inadequately.
The rating system shown in Table 1 should be used as a representative method for assigning a rating to each element. The rating is a relative measure of the strength or weakness of a particular maintenance process element .
TABLE 1. ELEMENT RATING SYSTEM Ratina Ratina Criteria "P" indicates that performance is EQ2B (inadequate or no effort has been made in this specific area).
"S" indicates that performance is SATISFACTORY (applicable elements of this program have been developed, documented, and effectively implemented) . Areas requiring improvement are approximately offset by better performance in other areas.
"G" indicates that performance is 'd.Q (more than minimal efforts have been made in this area, and this area has desirable qualities with only a few minor areas requiring improvement).
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1 In conjunction with the color coding, rate each element objectively.
Objective rating can be performed as follows:
- 1) Inspect the areas for each element as. identified in Section 4.
Unlisted' areas may be included as necessary.
2)' Consider the number of areas which will be used to rate the element. Using engineering judgment, rate each area under an element. See Figure 2 for exampie.
- 3) Using engineering judgment normalize the rating of each area for an element and mark the corresponding normal in the element box. For example (see Figure 2 Element 5.3), an element has eight areas of inspection. Five areas rated "S" or satisfactory, three "P" or poor, and two "G" for good. The normal rating for this element would be satisfactory as can be seen for the X in the box.
Generally, small differences in the ratings of elements can be reconciled through a normalizing process. This includes minor rating.
disagreements between several individuals on an inspection team. When major differences of color coding elements exist, the coding difference should be dealt with individually.
3.2 Element Ratina An element rating of a simple " adequate / inadequate" designation does not provide sufficicnt discrimination for the elements being rated.
To determine the rating for the overall maintenance process proceed through the following steps.
- 1) Rate each major element grouping using the criteria set forth in Section 4. Rating of the element should be the result of the degree of conformance to the criteria with the element implementation and rating on the bottom of the box. Figure 2 shows an example of a rating of a major element group.
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FICURE 2. RATINC PROCESS EIAMPLE
, e P - Poor ,,
. S - Satisfactory x f G - Good "O*
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P' tmAN SPECIAL PROCESSES S S ' U PROCEDURES e DETERED PLANT / K EXPOSURE CONTROL S WANTENANCE P' S' C NORMAL RATING ON THE IAW b e DDELNT/NAL
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- 2) When each element of a major element' group has been rated, roll up each element rating to the major group element box by putting the "X" in the box. This allows an overview of the rating distribution. Figure 2 shows an example of this process. Transfer the information to Figure 1.
- 3) When each major-element group'has been rated,'using engineering judgment, the process of determining the normal can be repeated for each level of the tree until.the top element has been rated. The top rating will be for the overall maintenance inspection for the plant.
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- 4. INSPECTION CRITERIA The anai'ytical tree (Attachment 1) is the means to systematically determine the~ effectiveness of a plant maintenance process. The elements of l the tree are identified in Roman and Numeric Style, i.e., I, II, III, 1.0, 2.0, 2.1, etc. Within this document, the Roman or Numeric characters shown on the Maintenance Evaluation Tree will be shown in paraphrases behind the sections below. This method establishes the correspondence between the document sections and the tree.
4.1 Overall Plant Performance Related to Maintenance (11 ,
Overall plant performance with respect to plant operability, equipment availability and general reliability can be related directly to the effective implementation of maintenance.
Inspection of plant performance should cover plant availability, operability, and reliability. These items should be determined from the plant's operating history, observations, and inspections of plant activities and appearance. Sources for obtaining the information for historic data are SALP, Performance Indicators, AE00-Scram, ESF Actuations, Technical Specification Violations, and Safety Systems Unavailability Studies, Monthly Operating Report Data, Capacity Factors from NUREG-0020 (the Grey Books),
LERs, and inspection reports. Data collection should be limited to those measures related to the maintenance process. The general condition of the plant should be determined during the plant walkdown inspection.
4.1.1 Direct Measures (1.0)
Direct measures of a plant's maintenance performance should be determined and rated. The inspection is to consider the following two areas.
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1 4.1.1.1 Historic Data i
The historic data should be reviewed and rated as to the impact maintenance has had. Consider reactor trips, ESF actuations, radiation exposure, technical specification violations, failure on demand, forced outages, percentage rework, work order backlog, failed surveillance, time critical in an LCO/ time critical, and the number of events and cases the licensee has attributed to maintenance activities. When inspecting this area, the following four general areas should be inspected and considered.
o Availability.
o Operability.
o Reliability.
o Radiation Exposure.
4.1.1.2 Perform Plant Walkdown Inspection (1.2)
Inspect licensee activities and plant condition to determine the extent to which the licensee has integrated the facilities, equipment, material control and plant condition into the maintenance process. Perform plant condition verification during a plant-wide walkdown, consider the latest licensee inspections reports, and verify closeout actions during the inspections. The following areas should be considered:
o General plant housekeeping, o Equipment and plant condition.
o Licensee walkdown inspections performed and documented. l o Spot licensee inspections conducted.
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. o Tagout logs and status board. A periodic review of the tagout logs l
l and status board to verify the equipment is out-of service for maintenance.
o Deficiency reporting methodology established and implemented.
o Deficiency follow-up and resolution methodology established and implemented.
4.2 Manaaement Support of Maintenance (11)
Good maintenance.is influenced by the management philosophy toward maintenance activities. The areas to be inspected are listed below. The inspections should be directed to determine and rate the extent that Corporate and Plant Management are aware and supportive of maintenance.
Applicable corporate, plant and engineering maintenance management should be interviewed, documents reviewed, unusual events analyzed, and Licensee activities inspected regarding each of the areas listed below.
4.2.1 Manaaement Commitment and Involvement (2.0)
The inspection of management commitment and involvement should be directed towards determining the emphasis management places on supporting and being involved with the maintenance process. The inspection is to consider the emphasis placed on nuclear industry programs and initiatives.
The management actions are to be determined, reviewed, verified and rated as to the effectiveness.
4.2.1.1 ADolication of Industry Initiatives (2.1)
Determine if the following issues are being addressed by management. If they are, inspect and rate the methods and the effectiveness.
o Self assessment.
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o INPO Maintenance Assistance Review Team Inspections and f'lant Evaluations'considering both the plant specific and generic issues raised during the inspections, o INP0 Outage Management considering planning, scheduling, modification control, maintenance and health physics.
o INP0 Significant Operating Event Reports (50ER).
o INP0 motor-operated valve initiative considering qualification, maintenance and failure issues,
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o INP0 Human Performance Evaluation System considering the impact of human errors on design, procedures, equipment failures, inadvertent actuations and trips.
Is management supportiva of participation in the following areas?
Consider the actions being taken. Verify the actioris.
o Maintenance Peer Evaluation Programs.
o INP0 Plant Performance Goals and Performance Indicators.
o INP0 Training Accreditation Programs.
o INPO Workshops.
o IS 0;dp::r,t Perf:m:r': !:pr:::::r.t "regrr TeMed pc, qqgg he=o A160Ay % Ryons o Owners Group participation and contribution to maintenance issues.
Determine if management established methods to address the following areas:
o The tracking, implementation, and review of the following documents:
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- - NRC Bulletins,. Notices, and Generic Letters ;
- NSSS Vendor Bulletins, Notices, and Letters
- Equipment Vendor Letters, Notices, and Bulletins J
- INPO Good Practices, Significant Event Evaluation and l Information Network (SEE-IN) f Part 21 Notifications. !
l o NPRDS input and using the NPRDS data for plant-specific issues.
4 o EPRI contribution and evaluation of maintenance issues, o NUMARC contribution and evaluation of maintenance issues.
o Determine the licensee's position and status of the philosophy of system engineering.
o Standards Groups (IEEE,- etc.) contribution and evaluation of maintenance issues.
4.2.1.2 Manaaement Vioor and Example (2.2)
Determine and rate by examining licensee activities concerning the extent to which management is aware of, or is involved with the following .
areas:
o Plant aging awareness.
o Self assessment including performance indicators.
o Training in maintenance, o Periodic maintenance program review and updating.
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o feedback to the organizations regarding maintenance.
o Have top managers demonstrated an interest in maintenance?
o Is the top management interest in maintenance known and reflected on all levels?
o How much visibility does maintenance receive?
o To what degree does management show interest, initiative, and participation in development, implementation and enforcement of maintenance policies?
o Determine the type of maintenance database system implemented (computerized or manual) and verify by sampling selected systems or components, the effectiveness. Consider the following:
Document irretrievably Document accessibility
- Ease of data manipulation The goal of the system and whether or not the goal is met.
4.2.2 Manaaement Organization and Administration (3.0)
The inspection of management organization and administration should be directed to determining how management supports maintenance activities, what long range (annual, semiannual) maintenance activity plan has been established, how the maintenance activity plan has been implemented and is being controlled, and how resources are being controlled. The inspection should be conducted by first determining the guidelines and then verifying by sampling of selected systems or components that the guidelines are being implemented as intended.
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4.2.2.1 Identify Proaram Coveraae for Maintenance (3.1)
Determine by examining work' activities, past and present, work schedules, maintenance work orders, etc., whether the following exist:
o Is a long range maintenance plan issued?
o is the maintenance plan kept up-to-date by controlled procedures?
o Is the maintenance plan periodically reviewed and updated?
o Does the maintenance plan include the following?
- Organizational layout and chain-of-command
- The personnel responsibilities identified
- A detailed description of the maintenance program and how business is to be conducted.
4.2.2.2 Establish policy. Goals, and Ob.iectives for Maintenance (3.2)
Determine whether the following exist:
o Are corporate and plant directives addressing policy, goals, and objectives for maintenance documented, issued, and approved?
o Do the corporate and plant directives address the following?
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- Periodic review and update
- Identification of the appropriate Codes, Standards, and Regulations
- Availability to the appropriate personnel.
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o Do the corporate and plant maintenance policy,' goals and objectives identify organizational responsibilities?
o Is programmatic. accountability established?
o How many and which individuals have reviewed the policies, goals, and objectives for maintenance to ensure compliance?
o Are the goals set by management for t'e n maintenance organization in conflict with the goals set for the other plant organizations? If so, how are the conflicts resolved.
o Interview a number of these individuals to determine their interpretation and how the requirements are implemented. Rate the effectiveness and consistency of the implementation by sr pling.
4.2.2.3 Allocate Resources (3.3)
Determine by reviewing the licensee's records, backlog and the rate by which maintenance activities are worked off. Consider the following:
o How well does management control resources for maintenance activities?
o Does management make a conscious effort to control the percentage of maintenance work performed by contractors, o Can it be determined that work is delayed due to understaffing of maintenance personnel?
o How much overtime is expended by maintenance personnel? Does it exceed NRC guidance on overtime?
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o Is maintenance' work delayed due to unavailability of materials?
1 o Is maintenance work delayed due to inadequate maintenance support?
.j 4.2.2.4 Define Maintenance Requirements (3.4)
Determine, by inspecting on-going maintenance activities, by sampling l- past and current work packages, and by inspecting licensee records associated with unusual occurrences, the following:
o Have the following activities been implemented in the maintenance process?
- Environmental Qualification required Preventive Corrective Emergency
- Predictive Diagnostic exam Surveillance testing
- ISI required Modifications.
o Verify that each maintenance activity is implemented as defined?
o Does each maintenance activity have governing procedures, schedules, and regulatory documents?
19 l
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a e a
o Does the maintenance process implement requirements from the following areas? Verify and rate by sampling selected systems and components.
~
- Vendor technical manuals
- Vendor Notices, Bulletins, and Letters l i
Part 21 Notifications
- NRC Notices, Bulletins, and Letters NRC commitments
- Technical Specification requirements Environmental Qualification documentation Seismic Qualification documentation
- Engineering analyses
- Maintenance history
- Industrial and Plant experience
- Plant operational status
- Radiological Controls
- QA/QC audits and inspections.
o Is a maintenance plan established for incorporating applicable document (vendor's manuals, EQ documents, etc.) changes into the maintenance requirements?
20
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o Is a maintenance plan established which governs and incorporates i modifications resulting from regulatory requirement changes, FSAR changes, . Technical Specification changes, etc. into the maintenance requirements and then the maintenance requirement changes into regulatory documents when appropriate? I 4.2.2.5 Conduct Performance Measurement (3.5)
Determine, by inspecting licensee records, sampling maintenance work orders, and by observing maintenance meetings and interface between maintenance and engineering staff, whether the following exist:
o -Is a maintenance activity plan established for periodic review of maintenance procedures, procurement, training, maintenance equipment and tools?
o Is there surveillance of t6,e above plan?
o Is work sampling performed?
o Are walkdown inspections of maintenance work performed?
o Is root cause analysis performed on identified maintenance-related failures?
o Is a feedback system established for maintenance improvement?
o Are maintenance performance indicators established and implemented?
o Is maintenance performance included in QA audits?
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p 4.2.2.6 Document Control System for Maintenance (3.6) 3 I
Inspect, by sampling of the flow of maintenance activities from initiation of work orders to the completion and close out of the work packages, to determir.e whether the following exist. Verify and rate the effectiveness of titplementation.
1 o Is a document control system established for the control of maintenance activities?
o Do proceduralized documents establish the following?
Responsibility for maintenance
- Accountability for work Authority Lines of communication
- Documentation requirements Required references
- Means of review, approval, and updating.
o Does the licensee document the control of maintenance activities and establish means for the following?
- Document modifications resulting from regulatory requirements, codes, standards, guidelines changes, and from plant and industry maintenance experience Assuring responsibility for changes 22 I
c; .; ....
Adequate levels of review for implemented changes
- Assuring proper changes to documentation.
o -Does the document control system establish traceability?-
o Is' the document control system periodically reviewed and updated?
4.2.2.7 Maintenance Decision Process (3.7) o J.
Determine, by inspecting past and'present licensee activities such as engineering support, studies, support activities from related functions, etc.,'whether the following exist:
o Is corporate management involved in and aware of decisions regarding maintenance activities for the following areas?
Maintain Upgrade
- Replace,
- Plant aging Work deferment.
o Is plant management involved in and aware of decision regarding-maintenance activities for the following areas?
Maintain
- Upgrade
- Replace 23 1
_ __ _ ______--_--.--- ____ _ _ . O
4 Plant aging Work deferment.
4.2.3 Technical S'uonort (4.0)
The effectiveness of the technical support organizations should be inspected with regard to maintenance. Review selected maintenance work i
orders, observe maintenance activities, and sample the preparation of work orders. Determine whether the following exist:
, o Established internal / corporate communication channels.
l 0 Established engineering support.
l o Integrated PRA into the maintenance process.
o Established quality control 1
o Integtated radiological controls into the maintenance process.
o Perform safety review of maintenance activities.
o Integrated regulatory documents.
Each of these areas is described in further detail in the following subsections. During the inspection, the effectiveness of technical support and communications should be considered.
The inspection should be performance based. Assure that work packages. l procedures and other documents are reviewed. In addition, interviews should be conducted with the department or organization manager and at least one other member of each department or organization (preferably at the worker level) . These interviews are to determine the policy, goals, and objectives and verify that they are being implemented. The results of the interviews 24
. . . .4-
.. ' should be verified by reviewing relevant licensee records and activities.
Examples of the applicable departments or organizations are as follows:
o Engineering (nuclear, I&C, mechanical, electrical, licensing, systems,etc.).
o Quality Assurance.
o Quality Control.
o Health Physics.
o Safety.
o' fire Protection.
o Operations.
4.2.3.1 Inspect internal /Coroorate Communication Channels (4.11 The extent to which each department or organization has established channels of communication between the corporate organizations and the maintenance organizations should be determined and rated. Information transfer, problem resolution, willful support, and mutual organization respect should be considered. The inspection should be performed with regard to the following:
o Identification and resolution of technical issues that are associated with maintenance. Some of the types of issues to be considered are:
- Design deficiencies l
25 1 .
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Construction deficiencies Failure determination Work planning and scheduling Failure analysis Procedure deficiencies Work order reviews Procedure reviews.
4.2.3.2 Jnspect Enaineerino Support (4.2)
The inspection should determine and verify, by sampling work orders, licensee activities concerning unusual events, etc., and the extent that engineering principles and evaluations are integrated into the maintenance process. Inspect the following categories:
o failure determination and analysis, o Preventive maintenance planning.
o In-house versus contracted maintenance, engineering support, analysis and testing. Include a review of any guidelines for determining which should be used.
o Material Qualification (substitution of materials). Consider the restrictions and the tracking of substitutions and replacements.
o The methodology intended to ensure compliance with 10 CFR 50.49 (EQ requirements) in the following areas: )
26 I
- Maintenance criteria identification from qualification documentation
- Implementation of maintenance criteria into werk documentation and procedure
- Accuracy of work documentation and procedures including future changes
- Work performance
- Work inspection
- Qualified personnel control
- Qualified materials identification, procurement, storage, usage and auditability from procurement to installation.
o The methodology to ensure compliance with the appropriate codes, standards, and regulations, as identified in the maintenance plan and corporate and plant directives.
o The methodology established to respond to or implement industry initiatives. Ensure the methodology is detailed enough to ensure that appropriate actions are taken and the appropriate personnel are involved.
o The snethodology established to ensure human factor considerations are implemented into the maintenance process.
o Radiation exposure reduction.
o Determine and rate the position.and status of the philosophy of System Engineering.
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o Determine the input and control provided for post-maintenance testing.
4.2.3.3 Insoect The Role of PRA In The Maintenance Process (4.3)
Determine the effectiveness, by sampling licensee activities, to which the following items are considered in all aspects of the maintenance process, particularly the areas of planning, scheduling, and prioritization of work.
j o Common mode failures.
l l o Single failure criteria.~
o Safety system significance.
l l o Component significance.
o Compliance significance.
te.2.3.4 Inspect The Role of Ouality Control (4.4)
Determine the extent to which quality control is implemented into the maintenance process. The following items should be considered:
o Criteria for inspection and audit have been established, documented, and used consistently. Verify, by sampling maintenance activities on selected systems and components, the following have been considered:
Frequency l
Hold / verification point criteria identified l
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{
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Acceptance criteria to be met Organization and qualification of individuals.
o Review several maintenance procedures, work orders, maintenance activities, and licensee records to verify that the appropriate hold points and inspections were performed. The types of activities that can be selected are EQ maintenance, surveillance testing, torque and limit switch ad,justments, setpoint verifications, etc. Verify that the required Quality Assurance audits and inspections have been conducted in the pa::t year.
o Verify that there is an established and documented methodology for reporting quality deficiencies to all management. Verify that the methodology is being used.
o Verify that quality deficiencies are being trended to establish that programmatic deficiencies have not developed.
o Verify that there is a methodology for ensuring that appropriate corrective actions to resolve deficiencies are taken and reviewed for adequacy. Verify this area by determining the status and reviewing the resolution of deficiencies identified in a number of the latest maintenance audit / inspection reports.
4.2.3.5 Inteorate Radiological Controls Into The Maintenance Process (4.51 s
j Inspect the extent to which radiological controls are integrated into the maintenance process. An inspection of selected work orders and procedures as well as observations of maintenance activities should be performed. Consider the following:
o Level Health Physics is involved in the planning and preparation to support maintenance work.
29
1 ...
o HP Training and Qualifications of maintenance and support personnel.
l -
Contractor maintenance and support personnel HP personnel ,
-- Job specific (i.e., mock up training).
o External and Internal E'xposure Control of Maintenance Workers.
Dosimetry Job coverage (RWP).
o Control of Radioactive Materials and Contamination Surveys and Monitoring including: -
Monitoring to support RWP issuance Total area controlled as contaminated.
o Maintaining Exposures ALARA including:
Source term reduction program 1
Worker awareness and involvement ALARA goal setting Scheduling of maintenance work.
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.. 4 c
. 4.2.3.6 Safety Review of Maintenance Activities (4.61.
t The extent to which safety is integrated into the maintenance process should be determined and inspected. This should include an evaluation of work ordgr5 and procedures, as well as, observing maintenance activities and following licensee actions in response to unusual occurrences. The evaluation should verify that there are documented guidelines which are used consistently. The following should be considered:
o Hazardous materials considering usage and storage, including the following:
Solvents and cleaning fluids Flammable materials Contaminated materials Irradiated materials Volatile materials.
o Electrical safety, o Fire protection.
o Entries into confined spaces and/or inerted atmospheres.
f 4.2.3.7 Intearate Reaulatory Documents (4.7)
Determine and verify how the licensee integrates regulatory documents into the maintenance process. The inspection should verify that changes to the regulatory documents are integrated into the maintenance procedures and work orders. Also, the inspection should verify that an organization or 31
- o. ..
individual has been assigned responsibility for this area and that all
- . documents are periodically reviewed and updated.
o FSAR.
o SER.
o Technical specifications.
o NRC commitments. ,.
o Generic letters, notices and bulletins.
o Applicable TERs.
4.3 Maintenance Implementation (III)
A good maintenance process is influenced by the quality of the established controls. The controls need to be both consistent with management policies, goals, and objectives and detailed enough to minimize confusion. This inspection method divides maintenance into four areas:
- 1) Work Control, 2) Plant Maintenance Organization, 3) Maintenance Facilities, Equipment, and Materials Control and 4) Personnel Control. The inspection should be directed to determine the extent to which documentation, maintenance organization, facilities, equipment, materials, and personnel controls are supportive of maintenance.
The inspection should be performance based and utilize the following }
considerations to rate the effectiveness of maintenance.
o Select a sample of systems or components tagged out for maintenance to check status of work and configuration controls.
o Sample a selected group of completed work orders to assess work control and involvement of support organizations.
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f- a- o Spot check parts and tools in stock; compare them to the tracking systems.
o Conduct direct observation of maintenance activities in progress.
o Conduct interviews with plant maintenance personnel and training staff. Verify contents of interviews by inspecting licensee records, guidelines, work orders, and other applicable activities.
4.3.1 Work Control (5.01 The inspection and rating of the work control process includes the subjects of work order documentation, equipment history, planning and scheduling, and document review.
4.3.1.1 Review of Maintenance in Procress (5.1) i Observe the performance of selected maintenance activities from the time the work order is received by the craftsmen until completion and closecut.
Verify that the following were adhered to:
o Were appropriate authorizations received?
- Management and supervision authorizations received including Health Physics, Security, Fire Protection, etc
- Proper operational personnel have been identified and a clearance issued.
f ,
o Was documentation issued and approved?
I, - Appropriate maintenance work orders have been issued and i approved 1
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The latest approved documents were used (i.e., vendor manuals, drawings, bulletins, Part 21 notifications, IE Notices, IE Bulletins, and procedures).
.o Were procedures followed? Consider items such as the followir.g:
l Work procedures followed
. System lineups were accomplished and verified l
Equipment properly tagged out of service and tagout procedures adhered to Adequate functional testing was performed before returning to operations for restoration Correct safety precautions were taken and authorizations received LCOs and surveillance were checked Housekeeping and cleanliness were maintained The personnel assigned where appropriate (i.e., performer, verifier, QC, foreman or peer)
Lifted leads and installed jumpers were properly identified Proper restoration of barriers and covers was accomplished, o Were qualified test equipment and tools used? Include consideration for calibration dates, identification of range and accuracies. Verify that instrument use is recorded on instrument documentation and work documentation.
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o Were the correct parts and materials identified? Include considerations for requisition and purchase order identification on work documentation. Checking parts out and in when not needed.
o Were discrepancies resolved when encountered?
o Was management oversight of the work adequate?
o Were personnel qualifications considered?
Qualification needs were identified Qualification was verified
- Personnel gealifications appeared to be adequate for task performance.
o ALARA work packages are established for maintenance activities where appropriate.
4.3.1.2 Establish Work Order Control (5.21 Determine whether the following, as evidenced by inspection activities, exist:
o Does the work order control provide for identifying need for maintenance work, for reporting it and for implementing the identified work?
o Does the work order document provide space for each of the following items? Is guidance provided for determining each item?
Sequencing numbers
- Component identification 35 o
~ _ - _ - _ . _ - - _ _ _ . . _ _ _ _ _ . _ _ _ _ _ _ . . _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _____
q ?
.\
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-' Descriptions of work Identification of crafts required Document package dating Job priority Safety and qualification requirements Technical Specification requirements i
Description of problems and responsible person for identifying them Does the work order provide for the identification of special process requirements, such as special work permits (welding, radiation, etc.), special work instructions, and special training and qualification requirements Does the work order provide for work instructions, hold points to allow inspections, or special-requirements; QA/QC; Safety; Health Physics; engineering; management; use of special materials or tools; and test instrument ranges and accuracy requirements Does the work order provide for identification of post-maintenance testing requirements Does the work order establish authorization requirements to commence work such as operations, maintenance, and work supervisors Does the work order identify craft personnel required to !
perform maintenance work 36 i
- - Does the work order require time and dating for work commencement and completion
- Does the work order control provide the following in the work packages: description of work performed, as-found conditions, repairs made, cause of failure evaluation, identification of special tools and parts., calibration data, setpoints, adjustments made, as-left conditions, any abnormal conditions, hold points, special reviews, and approvals for doing work?
o Does the work order control provide a method for tracking work in process? Verify accuracy during walkdown inspections by spot checking on-going work being supported by documentation. When work is on hold, verify status, o Does the work order control establish work completeness, work package completeness, work package documentation completeness, and any required follow-up?
o Does the work order control establish a proceduralized method to document, revise documentation, and perform emergency maintenance?
o Does the work order control provide control of surveillance and other procedure maintenance?
4.3.1.3 Maintain Eouipment and History Records (5.31 Determine, by inspecting mair,tenance work orders, the method of work order preparation and the combination of supporting functions to maintenance, whether the following exist:
o Is there a plan implemented for maintaining historical maintenance reccrds of equipment?
o Are historical records used to establish trending for maintenance purposes?
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--_2 -_--___m_-_-__.____._-_._
,'s . .'.
o Does .the trending process identify the following?
. Component /part System
~ Defective part Cause of defect (design, use, maintenance, etc.)
Changes needed for correction Maintenance adjustments.
o Is NPRDS data used and are failures reported to NPRDS?
o Are historical records easily accessed by a retrieval system?
o Are historical records used by engineering, planners, managers, etc?
o Are results of trending used for updating any analysis performed?
o Are maintenance records kept current?
o Do maintenance records document repair time?
o Are maintenance records closely correlated with the Master Equipment List?
o is the Master Equipment List maintained current?
o Does training emphasize use of maintenance history and equipment records for day-to-day operations?
o Are the maintenance records used in root cause analysis?
38 R E.T1- . . . . . _mmas.-w_.._m_.ama_ -
C.3.1.4 Conduct Job Plannino (5.4)
Inspect and rate, by observing maintenance activities, inspecting work -I orders, schedules, and work assignments, the following:
i o Are procedural controls established to assure adequate job ]'
planning?
o Are the procedural controls implemented?
o Does the job planning include the following considerations?
l
- Impact on safety l l
Coordination of activities ;
1 Completeness of work package (drawings, procedures. etc.) ;
Sequencing of job activities
- Tool /part availability I
- Qualification requirements Scheduling of personnel to perform job Specific processes such as time constraints, permits, qualifications, documentation, etc Occupational Radiation Exposure. i o Do the procedures provide for early coordination with the technical ]
support groups?
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i 1
4.3.1.5 Perform Work Prioritization (5.5) j l
I Determine, by inspecting selected work orders, the licensee's responses to unusual events, job planning, scheduling and supporting functions to i maintenance. Do responses address the following: l l
1 o Is work prioritization based on probabilistic risk assessment (PRA) criteria?
I o Is work prioritization performed in accordance with safety significance of work?
o Does work prioritization coordinate Balance of Plant (B0P) maintenance with its effects on safety?
l 4.3.1.6 Maintenance Work Schedulina (5.6)
Determine, by sampling work orders, schedules, and assignments, whether the following exist:
o Does the maintenance work scheduling process enhance maintenance activities?
o Does the maintenance work scheduling process control backlog of maintenance work?
o Are the following maintenance activities scheduled and controlled?
Preventive Corrective Predictive 40 1
.* ,\
.[ -
Surveillance EQ.
o Are maintenance activities scheduled to assure appropriate supervision and support?
o Are process conflicts considered in the scheduling process?
o Does the maintenance work scheduling process incorporate a tracking system for the following?
- Identifying maintenance requests being performed
-- Post-maintenance testing.
o Is a master maintenance schedule established to verify that-maintenance requirements, such as surveillance, EQ maintenance, ISI, and preventative maintenance are being scheduled?
o Does the maintenance work scheduling process control radiation exposure ALARA?
4.3.1.7 Establish Backloa Controls (5.7)
Determine and rate by inspecting licensee records, work orders, schedules, and plans the following:
o How have backlog controls been established and implemented?
o Is there control of deferred plant maintenance?
o is deferred maintenance work prioritized and is a documented justification provided by properly authorized management for allowing work to be deferred?
41 i
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4
. 4 o Are there time constraints established as to how long maintenance may be deferred?
o Are there any work packages being deferred that should not be, such as EQ maintenance?
o Is backlog reduced on the basis of prioritization and work significance?
o Does maintenance work scheduling contribute to maintaining occupational radiation exposure ALARA?
o Has the size of the maintenance staff been established to ensure backlog is maintained at a manageable level?
o What methodology'has'been developed to measure the backlog of maintenance activities and does it consider the following:
Ratio of preventive to corrective maintenance The number of man-hours required to reduce backlog to zero en all systems Ratio of safety related maintenance to nonsafety related Ratio of emergency to nonemergency maintenance.
o Has the maintenance backlog for 80P been considered integrated along with its effects on safety?
o What is the maintenance backlog as defined by all outstanding ;
preventive maintenance and corrective and measured in terms of
- 1) estimated manhours and 2) number of work orders?
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_ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ Q
- 4.3.1.8 Provide Maing nance Procedures (5.8)
Determine, by sampling maintenance procedures and inspecting the licensee's procedure writing, whether the following exists:
o Development / Approval of Procedures.
- Format developed, implemented, and used consistently
- Individuals identified for procedure development
- Review and approval cycle documented, implemented and used consistently
- Procedures contain at least personnel responsibilities, references and applicable documents, documentation requirements, acceptance criteria, detailed instructions, and identification of tools, instruments, and spare parts as well as any limitations on their uses (such as instrument and torque wrench sensitivities and accuracies and EQ requirements).
o Technically correct, consistent, and tested. Include considerations as to the steps to be taken if the procedure is deficient.
o Cautions and warnings included.
o Controlled. Incluae considerations for. methodology that only the latest version will be used and any necessary changes will be made.
o Periodic review and change process implemented.
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- r e 4.3.1.9 Conduct Post-Maintenance Testina (5,91 Determine whether post-maintenance testing criteria have been established, documented, and implemented with the following considerations?
o Assure operational readiness. Include criteria as to what is considered to be operationally ready and when testing is required.
o Identify acceptance criteria.
4.3.1.10 Review of Completed Work Control Documents (5.10)
Inspect, verify, and rate completed work control documents by sampling selected systems ar.d components. Consider the following:
o is the methodology for review of work control documents documented, implemented, and performed in a timely and consistent manner?
o Are completed work packages reviewed for completeness?
o Is the process for transferring and storing completed work packages proceduralized?
o Does the methodology for completed work include the following:
Closecut system considering a detailed review to ensure all appropriate actions (maintenance, inspections and post-maintenance testing) have been taken and acceptance criteria met Walkdown inspection performed when appropriate Feedback from the review process has been integrated into the maintenance process 44
ii. i. ,
Review recently completed maintenance requests from each of the three maintenance organizations (mechanical, electrical and I&C maintenance). Verify that the following were performed per the procedure requirements:
- Administrative approvals were obtained before initiating work
- Acceptance criteria was met
- Referenced procedures were approved and appeared adequate
- Inspections were in accordance with procedures and inspection records are completed
- The following were completed prior to turnover to operations; functional testing, adjustments, calibrations
- Qualified personnel performed the activity
- Contractor work was controlled in accordance with contractor control requirements
- Maintenance records are assembled, stored and retrievable as part of the maintenance history
- Affected documents are up-to-date (i.e., records, plans, drawings, instructions)
- Required 10 CFR 50.59' reviews have been performed and were adequate.,
4.3.2 Plant Maintenance Organization'(6.0)
The inspection of a plant maintenance organization should be based on observation of licensee activities and responses to unusual events, how the organization suppo'rts maintenance activities, how the maintenance activities ;
are controlled and implemented, how personnel are controlled, how the organization establishes documentation, and how open.the lines of !
communication between plant management and craft personnel are.
4.3.2.1 Establish Control of Plant Maintenance Activities (6.11 Determine the role the mechanical, electrical and instrumentation and control maintenance organizations have in controlling the maintenance activities in their respective area. The inspection should be directed to those areas listed below.
1 Determine whether the following exist:
o Has the mechanical maintenance organization established a methodology for the following?
Identifying mechanical maintenance needs Ensuring plant and mechanical system integrity is maintained Monitoring controls of maintenance activities
- Controlling rework and temporary repairs of mechanical maintenance. As an example: The use of unqualified parts when qualified are unavailable Controlling and implementing vendor technical manuals for maintenance, including review and update
- Training to assure job requirements do not exceed qualification of maintenance personnel 46 i __ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ -
. .Y..
- - Resolving qualification discrepancies detected during.
maintenance activities
- Implementing control of procedures used. Assuring proper and latest revision procedures are used in maintenance activities j
- Guidelines to allow portions of procedures to be marked not applicable when an activity may not be required for a particular phase of maintenance 1
- Controls on materials used in the maintenance process
- Controls on maintenance tools with respect to celebration and use l
- Configuration control to assure maintenance activities always returns a system to normal operating configuration
- Accountability of work performance, o 'Has the electrical maintenance organization established a methodology for the following?
- Identifying electrical maintenance needs
- Ensuring plant and electrical system integrity is maintained
- Monitoring controls of maintenance activities Controlling rework and temporary repairs of electrical maintenance. As an example: The uses of unqualified parts used when qualified are unavailable
- Controlling and implementing vendor technical manuals for maintenance, including review and update 47
1
. .i Training to assure job requirements do not exceed qualifications of maintenance personnel Resolving qualification discrepancies detected during maintenance activities Implementing control of procedures used. Assuring proper and latest revision procedures are used in maintenance activities Guidelines to allow portions of procedures to be marked not applicable'when an activity may not be required for a particular phase of maintenance Controls on materials used in the maintenance process Controls on maintenance tools with respect to calibration and use Configuration control to assure maintenance activities always returns a system to its normal operating configuration Accountability of work performance.
L l
0 Has the Instrumentation & Control (I&C) maintenance organization established a methodology for the following?
Identifying I&C maintenance needs l -
Ensuring plant and I&C system integrity is maintained Monitoring controls of maintenance activities Controlling rework and temporary repairs of I&C maintenance.
As an example: The use of unqualified parts used when unqualified are unavailable 48 L . . - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _
i# ;, 4' .
.r .
- Controlling.and implementing vendor technical manuals for maintenance,. including review and update
- Training to assure job requirements do not exceed qualifications of maintenance personnel
- Resolving qualification discrepancies detected during maintenance activities
- Implementing control of procedures used. Assuring proper and latest revision procedures are used in maintenance activities
- Guidelines to allow portions of procedures to be marked not applicable when an activity may not be required for a particular phase of maintenance
- Controls on materials used in the maintenance process
- Controls on maintenance tools with respect to calibration and use Configuration control to assure maintenance activities always return a system to its normal operating configuration Accountability of work performance.
4.3.2.2 Establish Control of Contracted Maintenance (6.2)
Determine, by observing selected maintenance activities performed by contractors, inspecting work orders performed by contractors, and channels of communications used by contractors, whether the following exist:
o Does the organization have policies and training for contracted personnel?
49
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- p ..
,p q- ,
'o - .Does selection of contract personnel incorporate factors such as the following?-
7 1 Education Prior. Experience Training Background and Physical Limitations.
o Is training provided for contractors in the following areas?
General Empicyment Training (GET)
Radiation' worker'
.EQ equipment Procedural-use Basic plant equipment Administrative procedures.
o Has the maintenance organization established controls to assure quality contractor work?
o Has the maintenance organization established procedural controls to assure that proper instructions documentation, and materials are used by contract workers?
o Has the maintenance organization established a program to determine contractor qualifications, monitor performance and accountability established?
50
a .4.3.2.3 Establish Deficiency Identification and Control System (6.3)-
Determine, by sampling work orden,, licensee records,- and observing plant conditions, whether:
o The maintenance organization established a process for identification and control of maintenance deficiencies.
o That process is followed by all plant and contractor personnel?
I o The identification process incorporates an easy and effective means of reporting and tagging deficiency items.
o The identification process incorporates the following:
- Responsibility for who is to identify deficiencies
- Proper procedures for resolution
- Failure cause determination.
o The identification program provides for review and approval prior to close out of a deficiency item?
4.3.2.4 Perform Maintenance Trendino (6.4)
Determine, by sampling the method of work order generation, inspecting selected repeat failures and reviewing present and past equipment records, whether the following exist:
o Has the maintenance organization established a maintenance trending program?
o Is the maintenance trending program proceduralized and documented
~
on the system, component, and part level?
51
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c *: .
l e o Does the maintenance trending program address the following areas?
Systematic fixes versus specific fixes Root Cause' Analysis Self Assessment / Performance Indicators Rework evaluation.
4.3.2.5 Establish Support Interfaces (6.5)
Determine, by observing' licensee activities and inspecting licensee operating practices, whether the following exist:
o Has the maintenance organization established an active interface toth support organizations?
o Does the support interface include the following?
Information transfer Problem resolution Willful support.
I o Does the support interface provide adequate communications with the following organizations?
Engineering Quality Operations
- Safety I
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s- 7 Location of the workshops within the plant in relation to other organization shops Work supervisor's offices in relationship to the shop area Organization (mechanical, electrical, and I&C) manager's office in relation to the shop area Adequacy of shop for working on contaminated / activated items Support organization (Engineering on and off site, QA, QC, HP, Safety, Fire Protection, and Operations) work areas with regard to the maintenance shops Parts storage and requisition Tool storage and requisition Relay testing and calibration lab Metering and calibration lab.
o Training an.o Mockup Facilities. Determine if the training and mockup facilities are available and adequate enough to meet the maintenance goals and objectives.
o Determine if the ALARA training and mockup facilities are available and adequate to meet the ALARA goals and objectives.
o Staging, lay down area and scaffolding should be available ar.d in sufficient quantities and space.
54
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. *) .-
a
- Health Physics
- Procurement?
4.3.3 Maintenance Facilities. Fouioment and Materials Control (7.01 The following areas are to be used to inspect and rate' the facilities, equipment, and material controls with regard to their support of the maintenance process. These areas are as follows:
o Provide maintenance facilities and equipment.
o Establish materials controls.
o Establish maintenance tool and equipment control.
o Provide control ano calibration of metering and test equipment.
o Perform plant condition inspections.
Interviews 'should be conducted with the maintenance, electrical, I&C, mechanical, and warehouse managers to determine the policies, goals and objectives. Following the interviews, inspections should be performed to determine the extent to which the plant practices, procedures, and layout support the policies, goals and objectives.
4.3.3.1 Provide Maintenance Facilities and Eauipment (7.11 The extent to which facilities and equipment enhance the maintenance process should be inspected and rated according to the following considerations.
o Facility arrangement and accessibility. Review the plant layout and personnel placer. ant to determine the extent to which they are supportive of the maintenance process. This review should include the following areas:
53
j.',
~
. o Communications systems should be available and arranged such that maintenance activities can be conducted without interfering with plant operations and controls. Areas that should be considered in f particular, are testing and troubleshooting of electrical and electronic circuits.
4.3.3.2 Establish Materials Controls (i.2) s Determine the extent to which material controls have been established for the enhancement of the maintenance process. The following areas should be included in the inspection.
l 0 Inspect and verify that policies and procedures have been documented and implemented for the procurement of parts and 4 materials. The following should be considered for parts and materials procurement:
- Guidelines should be available for ensuring a timely procurement of materials, including long lead time items
- Guidelines should be available for identifying required documentation, testing, inspections, and traceability of records
- Guidelines should be available for identifying required specifications of materials
- Guidelines should be available for identifying and expediting emergency procurement
- Acceptable sources, including their qualifications, should be identified
- Guidelines sheJd be available to identify the nuinber of spare parts (each type), the number control and reorder.
55
6 o' Guidelines and criteria established for identifying material shelf l j l life.
j o Spare parts identified. Guidelines should L,e established for spare parts: identification, and spare parts specifications should be f l
identified.
0 Identification of consumable materials. Guidelines'should be available for identifying acceptable consumable materials, such as:
i Solvents and cleaners !
Thinners !
Paints
- Oils and greases j
. Gasket materials
- Welding rods.
o Material and parts receipt and inspection. Guidelines should be established for inspection and the criteria to be met.
o Storage. The following should be considered when evaluating storage facilities:
- Separation of qualified and unqualified materials I
- Storage of hazardous materials. Include consideration of type, quality, where located, proximity to other materials and ]
equipment, and safety precautions 1
- Protection of stored materials and parts. Consider protection from harsh environments and other stored materials.
56
l s, In 4 s' ;
.o Verify that documentation.is traceable. Include consideration for j purchase orders, inspection documents, requisitions for use, and ]
installation work orders.
I o Issuance. Include consideration for requisition identification, work order identification, and guidelines and controls for returning if not used per the work order. ;
4.3.3.3 Establish ' Maintenance Tool and Eauioment Control (7.3)
Inspect, by sampling the licensee's activities and selectively sampling documentation, the extent to which tool and equipment control has been documented and implemented with regard to enhancing the maintenance process. The following should be considered:
o Identification methodology established, o Storage control (contaminated and noncontaminated).
o Tool maintenance, testing, and calibration. Consider items such as:
- Electrical lug crimpers Torque wrenches
- Dynamometers Lifting cables, straps, and ropes Pneumatic and electrical tools Breaker testing equipment.
i 57
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a o Issuance. Include considerations for who checks out equipment (contaminated and noncontaminated) for which work orders or procedure, the date checked out and date returned.
4.3.3.4 Provide Control and Calibration of Meterina and Test Eouioment (7.41 Determine, by inspecting licensee activities and documentation, the extent to which test and metering equipment is controlled and calibrated.
The following areas shotild be considered:
o Identification. of each piece of equipment (a unique identifier for each piece of equipment).
o Calibration, including the following:
Date calibrated and date due identified on the instrument and in the files Calibration of instruments information recorded and documented
- Calibration traceable to national standards
- Individuals, organizations, and companies performing calibrations documented.
o Control, including the following:
- Storage of equipment that ensures that defective instruments are segregated from good, special purpose instruments are segregated from general purpose, and equipment is stored so it is protected. Include consideration of contaminated equipment 58
L. .
s,' ,
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- - Issue / recall ensuring that individual checking out instrument, the work order or procedure where used, and the date out and date returned are recorded for permanent records. Ensure a recall ' calibration methodology is proceduralized and ;
implemented. ,
I l 1 Range and accuracy has been determined and recorded for each scale j o.
on an instrument. )
4.3.4 Personnel Control (8.0) i The following areas of review are to be used to inspect personnel control. The inspection should consider for personnel control, training, and qualification. Interviews should be conducted with management from the maintenance manager down to the work supervisor, the training and qualification manager, and the personnel manager. Inspections should be made by selectively sampling personnel qualification records and spot checking against work performed to verify qualifications.
The inspection areas are as follows:
o Establish staffing control.
o Provide personnel trainiag.
o Establish test and qualification process. Identify qualification criteria to be met by all levels of the maintenance organization and how qualification is assured.
o Assess the current personnel control status.
4.3.4.1 Establish Staffino Control (8.1)
Determine the extent to which personnel control is proceduralized and implemented into the maintenance process. The following areas should be inspected:
59
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, - j, ;., . .
- l, -
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o Hire, fire, and promote policy including the following:
' Education
- Expe'rience Physical characteristics
. Training Certifications.
o Organization chart, including the following:
Available
- Up-to-date Ratio to work backlog. Methodology established for minimizing backlog Supervisur/ worker ratio Emergency maintenance.
o Personnel action for individuals that violate maintenance or support group procedures. Review the following:
Number of Radiological Occurrence Reports attributable to maintenance workers Recent personnel actions (if any) against maintenance workers.
60
.L___ _ -_ _ _ _ _ - - _ _ _ _ _ - . _ _ _ _ _ - - - _ - _ - - _ _ _.
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o' Turnover minimization policy established, including the following:
- Salary Benefits Training, Education enhancement
- Overtime.
o Shift coverage control.
o Job descriptions,-including the following:
- Available for all positions and up-to-date
- Periodic review and update
- Detailed enough so confusion and. duplication of effort will be minimized
- Periodically reviewed and updated.
o Description of types of crafts and their responsibilities.
o Number of personnel. Methodology established and documented including the following:
- Normal conditions including provisions for training
- High demand conditions such as refueling and shutdowns.
o Emergency maintenance control.
61
l -- s ,i
, 7. ; ..
s 4.3.4.2 Provide Personnel Trainina (8.2)
Determine the extent ~to which training is implemented and documented in the maintenance process. The following areas should be considered for all organizations (plant and contractor personnel) involved in the maintenance process; o Does the licensee have INP0 accredited training and qualification program?
I o Generas. Consider procedures, GET, plant systems, and radiation protection.
o Specific. Consider specific training for activities within a particular organization. '
o Safety related. Consider any precautions or special criteria for maintenance on safety-related systems or components.
o Special work, such as welding, cutting, meter and test equipment i calibration, etc.
4.3.4.3 Establish Test and Qualification Process (8.3)
Determine the extent to which testing and qualification of maintenance personnel are integrated into the maintenance process. Consider the following:
o Format is approved and documented.
4 o Personnel qualifications are documented.
o Personnel qualifications are traceable.
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