ML20248J539

Rev 0 to MWC02, Fermi 2 Work Control Conduct Manual

ML20248J539
Person / Time
Site:	Fermi
Issue date:	06/09/1997
From:	Shelton D DETROIT EDISON CO.
To:
Shared Package
ML20217H660	List: ML20217H667 ML20248J539 NRC-97-0088, Forwards Response to 970703 RAI Re License Amend to Extend EDG Allowed Outage Times.Response Includes Descriptions of Current Plant Procedures & Practices Which Makes Changes as Necessary
References
MWC02, MWC2, NUDOCS 9708130175
Download: ML20248J539 (75)

Text

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3 Work Control Conduct Manual (d

39gj MWC02 Revision 8 Ed.ison WORK CONTROL l s nA\N Revision Summary 03 6 #

1) Revised appropriate sections to introduce the use of the Work Request Tag (WRT).

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2) Deleted statement in Section 3.6.1 which stated that the FIRST could generate their own RWps.

3) Added sentence in Section 3.7.4 to state Work Requests that perfonn alterations other than described by engineering documents (EDPs, TSRs Temp Mods) shall be retumed to the As Found (and safe) condition prior to de activating or signing off the Work Request.

4) Changed Cll$0 to Cl103 in Step 4.2.2.12 to correct number for llCUs.

$) Revised 4.4.6.10 to also review special ALARA considerations and general radiological conditions.

6) Added 4.5.1.11 to verify Work Request Tag has been removed after the job.

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7) Revised Enclosure A to delete specific section called out for 35. CON.020.

8) See revision bars.

(G) Implementation Plan

1) This chapter goes into effect 7 days after approval.

2) An electronic message will be mailed sitewide to announce the changes in this revision.

In addition, Infonnal Training will be used to train Maintenance personnel and a Night Order will be used to train Operations personnel.

0%Y gg0@, goM Enclosures A QA lloid Point Matrix information and Procedures D5N Resision DCR# DIC File #

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, A Work Control Conduct Manual MWC02 px Chapter 2 Work Control Revision 8 Page 2 4

1.0 PURPOSE

[CMl l SOER62001 1 hts DER uus urutten against SOER S2-001, Radsation overexposure of Alaintenance RCI, RC2, RC3 Personnel, to ensure that currentprograms efecthely cover events listed in the SOEK in DER 88 062 response to thu DER nso PDCs uere initiatedandit was determinedthat currentprocedures adequately address the INPO recommendations Od AIR 339 lhis DER was issued to track the review of O& AIR 339for apphcabshty ofrecommenJations DER 891997 following a reactor trip caused by cleaningflow transmitter vent valves. The review determined that NPP At4101 andNPP PSI.01 provide adequate instructionsfor initiating a uvrk request andprovide guidancefor planning uvrk No changes were made in response to this DER NOTL b2 03) in response to IE Nonce 62 31, lh eresposures in PWR Cavities, Fermi conducted and documented required readingfor the Noticefor sh$ supervisors, senior reactor operators, and orher ident@cdcandidates. Completion ofthe requiredreading uns documentedper EF2 69134 andEF2 62491. No changes were made to the uvrk controlprocedure as a result ofthis Notice SERbV0)2 In respome to SER 69-012, Electrical Phase Reversal to Control Rod Drtre Alechamsm Results DER 89 0383 in Reversed Rod Drive Afotton, fermi's evalua: ion concluded (DER 89-0383) that existirm procedures adeq.tately address the recommendations ofthe SER on PAiTandcomrol ofIped leads. and no action uns required No procedure revisions uere made in respc;nse to this SEK SOER 82 006 SOER 82 006 addresses the emproper operation ofSafety Related Reliefl'ah es iSRRI't caused RC) by improper adjustment andinstallation ofinternalparts Recommendations 3 and 3 recommendplant maintenance procedures be revleurdin order to minimi:e the possibth 0 ' of O< similar occurrences happening at fermi 2. Upon re iew ofthe maintenance procedures. Termi concluded (EF2 65384) that "supicient Quali0 Control. Post Alaintenance Testing andsafety or personnelandequipment has beenp oridedfor uvrk beingperformedby the Afaintenance Section personnel

• No changes to entsting procedures were made in response to this SOER DER 94 0020 Thus DER was issued due to maintenance recordsfor securstv related equipment not properly retainedas required by 10CFR73.70 and the PSP. Corrective action was to conduct training on the requirements ofAfWCO2 (NPP Att101E DER 94-0213 in response to this DER which was issued due to approved ECRs not incorporated onto the unrk request, one corrective action ws to revise the procedure to provide better guidelinesfor the userslu ork group supervisors regarding the control of uvrk packages.

DER 94 0324 1his DER uas issued to evaluate SER 6-94 u hoch deladed an event caused by madequate SER 6 94 contractor control, inadequate uvrk controland urakjob planning The evaluation concluded Ihat in add tion to the FBP u hich prescribes adequate contractor control, Ihe u ork control procedure ensures that alljobs receive Fermt oversight and. in some cases, ajourneyman remains on thefob as an addstionalprecaution.

94091 A uvrk controllaskforce was createdto review the work controlprocess(94091), includmg the 94090 Al.Sprocess (RAC15 94090). This group evaluated the processes and revised the work control and ALSprocedures to implement recommendations ofthe task)q DER 92 0433 in response to this DER uhtch was assued due to a contamment brcach that occurred during a shutdown, the work controlprocedure was revisedto clar& review ofimpact Statements, requiredplant conditions, equipment release (f<v work), define plant impact codes, prohibit the use ofNSS holdpoints, describe the requirementsfor uvrk package modfcation. prohibiting open ended troubleshooting steps, require documentation ofspec@c plant' system component condaions necessaryfor work. and to prohibit uvrk request deactivation u hile personnel protection is on efect.

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Work Control Conduct Manual MWC02 r

Chapter 2. Work Control Revision 8 Page 3 To prescribe the methods for controlling maintenance and modification activities.

2.0 SCOPE 2.1 This chapter applies to maintenance and modification activities performed on structures, systems and components.

, a 3.0 WORK REQUEST 1NITIATION AND DOCUMENTATION REQUIREMENTS l 3,1 Work Request initiation Form (WRIF)/ Work Request Tag (WRT) 3.1.1 Site persormel may request work on a defective plant component through the use of a WRIF or WRT.

1. The WRIF is a computer generated form that may be completed by site personnel to req'iest either Minor Maintenance or work that must be completed through planned Work Requests.

2. A WRT is a two pan tag that may be filled out by site personnel upon discovery of defective equipment in the plant. Once completed, the first part

' of the tag is to be processed instead of a WRIF and the second part of the tag is to be used to identify the defective equipment (by hanging it on the defective equipment, or, for equipment located in liigh Radiation Areas, High Temperature Areas or the Drywell/ Torus, posting it at the entranceway of these areas to maintain personnel exposure ALARA, ensure personnel safety and minimize plant operating concems).

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3. At a minimum, the WRIF and WRT should contain the following information:

a. Identification, by complete PlS number, noun name and location, of the structure, system, or component requiring maintenance

b. A clear and detailed identification of the problem including how the problem was found and cause,if known

c. Individualidentifying problem O

V 3.1.2 A WRIF is not required for work to be performed as Toolpouch Maintenance (see MMA02).

's 's Work Control Conduct blanual h1WC02 Chapter 2 Work Control Revision 8 (o] Page 4 3.2 h1(nor h1alutenance Form lCMl _

DLR V) 0228 in resporue to Ihu DLR which was usveddue to a turhne trap "near mtss " on a minor maintenance uvrk order, theprocedure uns revisedto address minor maintenance routing and responsibilities ofboth Work Control and Maintenance NOTE: The first part of a Work Request Tag (WRT) may be stapled to a form similar to the Minor Maintenance form and used for minor maintenance.

3.2.1 Minor Maintenance form is used to perform maintenance activities that do not l require step by step work instructions. All Minor Maintenance activities must meet the conditions listed below.

1. The component is not Ql, QlM, EQ, ASME, Technical Speellication, or seismic or, ifit is, the portion or part being worked does not perform or affect a Ql, QlM, EQ, ASME, Technical Speellication or seismic function.

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2. Welding will not be performed on structures, systems, or components of Ql, EQ, ASME, Technical Specification or seismic classification.

3. Detailed planning is not required and work is within " skill o6the cratt"

4. Detailed post maintenance testing is not required.

(CMl DLR V4 03]I Thu DLR was usued to evaluate SLR 94 007, Pressure Instrument Taps Capped SER 94 007 Durnng Minor Maintenance. to determine whether Termt 2 adequately adJresses the recommendations ofthis SER. Termi's evaluation concluded that the wark control procedure contains checks to prevent unauthorised work being performed as minor maintenance.

3.2.2 Upon receipt of new WRIFs, FermN Integrated Resource Support Team or Work Control personnel will review for t. 'uation of problem, possible consequences, plant condition required, and whether the work scope is suitable for minor maintenance. Consultation with Operations and Maintenance personnel is recommended. If, upon evaluation, the work scope is determined to be suitable for isstance as a Minor Maintenance item the following actions are required:

1. Supervisor Work Control signature is required on the WRIF prior to commencing work in the field (obtaining per Telecon is acceptable). During off shift hours, the NSS may authorize the minor maintenance to be worked, p)

( UNDER NO CIRCUMSTANCES IS WORK TO COMMENCE IN T11E FIELD WIT 110UT OBTAINING Tills APPROVAL.

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Work Control Conduct Manual MWC02 Chapter 2 Work Control Revision 8 Page$

2. Work Control is to change status of the WRIF to minor maintenance.

l 3. Operations work control /RTC should review the niinor maintenance form for plant impact.

4. Work Group Supervisor is responsible for ensuring the following actions are l completed:

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a. Review and walkdown of work.

b. Entering appropriate work steps on the minor maintenance form, as required,

c. Ensuring work does not progress to any additional operational impact.

d. If work has a previously identified operational impact, ensuring Operations personnel are aware of this impact and agree to work.

, c. Assigning work as manpower and plant conditions permit.

f. Ensure applicable procedures are followed (e.g., foreign material exclusion and interim alteration checklist procedures)

5. For work performed by Fermi's Integrated Resource Support Team (FIRST)

a. FIRST Supervisor (or designee) will sign as General Supervisor,

b. FIRST Supervisor (or designee) will sign as Maintenance Supervisor.

c. FIRST NSS will sign as operations for release and retum to service.

6. Forward WRIF bnek to Work Control if any of the following are encountered,

a. Unable to complete the prescribed work,

b. Review and walkdown of work identifies additional potential for significant operationalimpact.

3.2.3 Upon completion of minor maintenance work, close out of the package is to include documentation of all work performed, M&TE used and material used in Section 4 A of the Minor Maintenance Form.

1 Work Control Conduct Manual MWC02 l

Chapter 2. Work Control Revislom S Page 6 l

3.3 Work Request Form 3.3.1 The Work Request Fonn is a computer generated form used to document maintenance and modification activities. At a minimum,it shall contain the following information:

1. QA classification of component

2. PlS nurnber and the serini number for replacements, where available, of the structure, system, or component upon which maintenance is to be performed

3. For corrective maintenance, a description of the conditions found and the cause if known '

4. Supporting procedures, checklists, data sheets, and drawings to be used to perform the maintenance 5 A description of the work performed if procedures were not used or if the comple',ed procedures do not provide an adequate description

6. IdentiDcation number and calibration duc date for any Measuring and Test Equipment (M&TE) used

7. All consumables, materials, and spare parts used in sufficient detail to permit traceability

8. All post maintenance testing performed and the results

9. Individuals performing, reviewing, and approving the maintenance or modification activity 3.3.2 - Maintenance or modification activities performed on plant systems, structures or components that require detailed step by step instructions shall be completed through planned Work Requests.

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Work Control Conduct Manual MWC02 p Chapter 2. Work Control Revision 8 V Page 7 lCMl blR 67 03H 1his DLR uas assueddue to an ASAtt and soleprocedure violation in uhtch l replacementparts utre Installedprior to aproper repair / replacement evaluation in response to this DER, theprocedure was rnisedto address the may in uhich an *E" Order Repair / Replacement Program is generated Specfflcally thefollouing run statements urre added: (1) When an *E" Order is uritten that will qfect Ihe health andsqfety ofthe public, a Repair / Replacement Program will not be requiredprior to uvrk proceeding in thepeld The Repair / Replacement program shall be processed as soon as possible; and(2) For all other orders efecting AShiE eystem' components, the ASAIE Code must still be adhered to regardless ofassigned uvrk priority. A Repatr/ Replacement program shall be written to cover the uork performed in thepeld prior to the unrk being performed 3.3.3 The NSS has the authority to direct work activities be performed without an l authorized Work Request (for example, Priority E). All such rnalntenance shall be documented during the work and appropriate reviews and approvals obtained upon l completion of the work.

3.3.4 At the discretion of the Supervisor, Planning, Work Packages may be divided into sub packages where work is extensive (for example, many components or many locations, or several work groups are involved; see Section 4.10),

3.3.5 Measurements do not require a Work Request. They are covered by MES31 Diagnostle, Special and Infrequently Perfonned Tests or Evolutions.

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DLR bV-UV76 in resporue to this DLR uhich uas issued due to an snstrument being returned to service without;voyer package review, theprocedure nas revisedto snclude review steps (by the WGS. PQA and the NSS) upon completion ofucrk in one dtvision prior to releasing ucrk in the other division.

3.3.6 Technical Speellication related work packages should be prepared for:

1. One division for inoperable or out of service equipment

2. One channel per division for operable equipment

3. If the :omponent to be worked serves a mutli channel / divisional function, the Work Request may include both channels' divisions.

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Work Control Conduct Manual MWC02 g Chapter 2. Work Control Revision 8

( Page8 3.3.7 Generic Work Request may be used to perform repetitive maintenance on similar type equipment (e.g., Security MRRs, repair EDO alarm cards, cleaning Circ Water Pump llouse Screens). These Work Requests, after initial approval from the NSS, do not require subsequent sign ons. A verbal notification is sufficient. For repeated work (sign ons), the NSS rnust signoff all return to service entries for each activity except security items.

l 1. Generic work request are limited to 10 work activities. After 10 activities have been performed the work request will be closed out.

2. PlS numbers for each work activity performed under a Generic Work Request shall be added to the Pls Numbers screen in WST for the Generic Work Request.

3. The Generic Work Request will contain the Impact Statement, Job Instructions, Post Maintenance Testing, and supporting documents, as required.

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4. The WRIF for a Generic Work Request can use a " Generic" PIS number and problem request description.

3.4 Adherence to Work Request Instructions, Procedures, or Drawings 3.4.1 Maintenance activities on plant systems, structures or components shall be performed in accordance with approved procedures, written instructions and/or approved drawings suitable for the task to be performed.

[ cat l OLR 90-466 in response to NRC unresolved stem 90-009-03. the proccJure n as rensed to state:

90361

" Steps in maintenance and testing procedures u hich are not to be performed in their entiren that are apphcable to the tasi being performedshall be designatedprior to performing Ihe procedure in thefield Allappropriateprecautions andprerequisites shallbe observed "

3.4.2 Steps in maintenance and testing procedures which are not performed or not performed in their entirety shall be identified with a brief statement of explanation prior to performing the procedure in the field, marked Not Applicable (N/A) and initialed and dated. Appropriate precautions and prerequisites shall be observed.

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! Work Control Conduct Manual - MWC02 Chapter 2. Work Control Revision 8 Page 9 -

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91227 in respome to violation 91002 02. documentation concerm with workpackages, the DLR 9106I8 procedure was revised to state that work package istructiom steps do not hm to be -

followed sequentially unless so indicated within the body ofthe instructlon.

3.4.3_ Work instruction steps do not have to be followed sequentially unless indicated otherwise within the body of the instruction. Work activities associated with specific QA hold points shall not proceed beyond a point at whhh the inspection can be performed or witnessed snd documented as satisfactory by a qualified inspector, 3.5 _ Work Request Documentation Requirements 3.5.1 Sign-offs contained on vaultable parts of the Work Request, including signature and initial blocks, shall be either signed off or marked N/A and initialed and dated upon completion of the work. Computer generated N/A blocks need not be initialed and dated.

1. Items in the Work Request that are blank and are obviously not applicable for the work prescribed by the Work Request are not required to be NA'ed and-O- initialed. (A few examples include the Cancellation portion on a completed Work Request and the CRIS Dot Removed block when a CRIS Dot is not applicable).

3.5.2 Any changes to previously signed or initialed blocks shall be single lined out,

-initialed, dated and accompanied by a brief description of the change.

i 3.5.3 Work Request implementation shall be in accordance with the steps of this chapter, 3.5.4 - Corrective Maintenance (CM) can only be added to a Preventive Maintenance (PM)

Event to correct deficiencies identified during execution of the PM. Under no other

. circumstances shall Corrective Maintenance be added to a PM Event.

' 3.5.5 _ Shop Work is any work which is to be performed that does not :Sct installed plant systems, struc'.ures or components and may be performed without NSS permission.- -

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Work Control Conduct Manual MWC02 Q_ Chapter 2. Work Control Revision 8 V Page 10 3.6 Fermi's Integrated Resource Gupport Team Requirements ,

3.6.1 The FIRST is a multi-discipline team that has the capability of repairing minor plant deficiencies in a self sufficient manner. Work Assigned to the FIRST is expected to be complete in less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The FIRST will usually prepare its own work packages, LCOs and STRs and place and remove its own protective tags. Work selected for the FIRST is to be less complex and, therefore, not require the level of control necessary for more complex repairs.

3.6.2 Personnel assignments to the FIRST should be for one fuel cycle. At the request of the FIRST Supenisor, each organization shall assign a replacement to fill in for vacations, shift rotation and training requirements. Unexpected absences will be ~

filled at the discretion of the FIRST Supervisor based upon the anticipated needs for the period. The FIRST may request assistance from other organizations as required.

i 3.7 General Requirements i n

j V 3.7.1 Anyone who identifies a plant condition that would cause non-compliance with Technical Specifications, Operating Procedures or Plant Orders, shall immediate!y l

notify the Nuclear Shift Supenisor (NSS).

I 3.7.2 Any person identifying a Condition Adverse to Quality (CAQ)(as defined in MLS02, Deviation and Corrective Action) shall initiate a Deviation Event Repon (DER).

3.7.3 If a PM job cannot be performed by the PM Critical Date, the individual making that determination shall initiate a PM Change Form (see MMA03, " Preventive Maintenance and Periodic Calibration and Testing") or DER (see MLS02,

" Deviation and Corrective Action").

3.7.4 All personnel performing work in the plant shall ensure that the actisity being performed does not introduce any unauthorized modifications into existing plant systems, sub-systems or components that will remain in place after Return to Senice. Modifications such as lifting leads, installing jumpers, installing / removing blind / blank flanges, spool pieces, setpoint changes, etc. shall be identified as such and controlled in the package by approved procedures, Engineering Design Packages (EDPs), Technical Services Requests (TSRs), Temporary Modifications, Interim Alteration Checklists, or Test Instructiont Work Requests that perform g alterations other than described by engineering documents (EDPs, TSRs Temp i

Mods) shall be returned to the As Found (and safe) condition prior to de-activating or signing off the Work Request.

Work Control Conduet Manual MWC02

. Chapter 2 - Work Control Revision 8 -

% Page 11 3,7.5 All Work Requests (except shop orders) and minor maintenance forms (WRIFs) shall be reviewed, approved and released by the NSS prior to work.

3.7.6 Each WRIF shall have a preliminary review performed to determine whether the problem identified is a system, structure or component (SSC) Functional Failure as defined by ;he Maintenance Rule. Mark the appropriate block on the WRIF and forward a copy to System Engineering, 3.7.7 If a Maintenance Activity is considered to be a test or design verification, an SOE (Sequence of Events) must be considered -- and should be discussed further with the appropriate System Engineer. The SE will review MES31 if there is a concern that this proposed Maintenance Activity may be considered an SOE, Special Test, or IPTE.

l 3,7.8 A Level 3 DER may be " Closed to Process"(CTP) using a Work Request provided the Work Request has been initiated and a CTP link has been established in the database.

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Work Control Conduct Manual - MWC02 O Chapter 2 - Work Control Revision 8

- Page 12 4.0 PROCEDURE 4.1 Initiating a WRIF/WRT Person Step Action Responsible lCMl SOER 54-003 RCI in response to recommendation I (Ensure that operating and maintenance practices l require prompt repair ofleaking pressure boundaryJoints in systems containing borated water.) to SOER 84 003. Fermi concluded that existing provisions wre adequate to address the intent ofthe recommendation (EF2 71422). Piping containing the sodium pentaborate solution is provided with bolted connectionsfor flanged equipment and detection ofleakagefrom thesejoints is accomplished by visual inspections or by tank level monitoring. The Fermi response stated that "any person who discovers a system or component in need ofrepair, to document that needfor on a maintenance order in accordance with the Procedure 12.000.13. " This procedure was superseded by NPP-mal.01. No change were made to the work order procedure in response to this SOER.

lenitiator l 4.1.1 Identify plant equipment requiring maintenance.

linitiator l 4,1,2 Complete a WRIF to request maintenance, or, if defective equipment is discovered in the plant, complete a WRT identifying the defective equipment.

1. De as specific as possible when completing information on either form, including how the problem was found and cause, if known.

Provide an accurate equipment location.

NOTE: For defective equipment located in High Radiation Areas, High Temperature Areas or the Drywellfforus, WRTs are not to be hung on the equipment in these areas. Instead, they are to be posted at the entranceway of these areas to maintain personnel exposure ALARA, ensure personnel safety and minimize plant operating concerns.

2. If using a WRT, complete the tag information, hang the back part of the tag on the defective equipment or post at the room entrance, as appropriate, then detach the front part for processing.

3. For WRIFs for failed surveillances, include a copy of the SPF and :

a copy of the failed section of the ' surveillance,

.]v 4.1.3 Submit WRIF or front part of WRT to the NSS for review.

Work Control Conduct Manual MWC02 g Chapter 2. Work Control Revision 8

( Page 13 wucs esain 4.1,4 Review WRIF/WRT.

sue.rvisort l NAst

1. Verify Initiator's WRIF/WRT entries are complete and include all l information as identified in step 4.1.2. If description of problem is unclear, or required information has not been provided, return WRIF/WRT to Initiator for resolution. l lCMl DER 881483 This DER uns issued due tofailure to cross reference the DER on the Work Request and takefollon.up actions on incomplete work. Aspart ofthe correcthe action, the procedure uns revised to address the DER H cross relation on work requests.

2. Have related documents (such as LCO, CRIS Dot, DER, or TSR) initiated.as necessary and record related document numbers on '

Work identification part of WRIF or WST.

nuci rshin 4.1.5 Assign a Priority to the top of the WRIF/WRT.

supervisor / l NAss/Oper.tionW

! maint.n.nc. work 1. Use the following definitions to assist in determining WRIF/WRT l

Priority:

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') a. Priority E - Extreme personnel hazards, threats to public safety or immediate threats to continued safe operation of plant. Priority E WRIF/WRTs shall be processed and work l commenced and completed as soon as possible.

b. Priority 1 - Urgent (Plan and work immediately)

Definition: Those items that have a near-term direct impact on the health and safety of the general public, the reliability of power generation, or industrial safety.

Examples: This classification includes: T/S LCOs s 7 days, loss of plant capacity 2 50 MWe, or affects the ability of the plant to respond to emergency or accident conditions.

Specific examples include:

- T/S LCO ofs 7 days

- T/S Action Step requiring a power reduction

- Significant loss of security systems, or plant lighting requiring compensatory measures

- Significant loss of fire protection capability 1

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Work Control Conduct Manual - MWC02 rs Chapter 2 - Work Control Revision 8 Page 14 Work Control Response - Work authorized on a 24 hr/ day - 7 day / week basis required to support p. ant reliability, capacity or availability. These items will be planned as emergent and work will start within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

c. Priority 2 - Emergent (Expedite Schedule)

Definition: Those items that have a reasonablep' ossibility of affecting safe, economical, reliable and environmentally sound plant operations.

Examples: Those work itemsjudged to have a possible impact on safe, reliable and environmentally sound plant operation which includes activities that affect S AT.P i indicators, and plant capacity of 2 5 MWe Specific examples include:

- Loss of 2 5 MWe

! - Surveillance test support work identified during testing

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- LCO conditions > 7 days

- Personnel safety issues

- Security Non-compensatory Measures Work Control Response: Expedite schedule; plan and work as soon as possible, Generally, work activities that cannot be delayed until the next scheduled work window. These items will be reviewed by Scheduling, implementing organization and Operations managers for schedule impact and scheduled within 4 weeks provided no restraints exist.-

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Work Control Conduct Manual MWC02 Chapter 2 - Work Control Revision 8

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d. Priority 3 - Routine (Plan and Schedule per 13 Week or Outage Schedule)

Definition: Those items which do not have a significant impact on safe, economic, reliable and environmentally sound plant operation.

Examples: Those items that are routine activities which can be planned and scheduled in accordance with the normal work control process for developing the rolling on-line schedule and outage schedule. Specific examples include:

- BOP equipment repair

-Items not causing active LCO conditions

- Preventive and conective maintenance to improve reliability

- Backlog reduction items

- Most major / minor modifications Work Control Response: Plan and schedule per the rolling on-line schedule or planned outage (generally scheduled outside the 4 week window).

e. Priority 4 - Nonscheduled Definition: Work items which are not scheduled and not Priority E or 1-3.

Examples: These items are either Minor Maintenance, Operational Support, or Maintenance Support related activities that do not require the activity to be scheduled in order to work the activity.

Work Control Response: This work is generally not scheduled; it will be worked as " fill-in" and controlled by the Work Group responsible for implementation.

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Work Control Conduet Manual MWC02 Chapter 2 - Work Control Revision 8

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( _ Page 16 gag 4.1.6 Enter WRIF/WRT information into Work Scheduling Tracking System (WST).

1. Forward WRIF/WRTs to FIRST (or work control planning) for Teview.

[sasr l4.1.7 Meet and discuss new WRIF/WRTs.

1. Designate responsible Work Group.

2. Assign team to investigate WRIFs requiring further review.

(Investigation will normally take less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.)

3. Determine which WRIFs can be worked as Minor Maintenance in accordance with Section 3.2.

4.1.8 Forward all WRIF/WRTs not being worked by the FIRST to Supervisor Planning.

sup.,viso, 4.1.9 Have Priority E,1 and 2 related Work Requests added to the Plan of the Scheduling Day (POD)/WST, provided no work restraints exist O

Work Control Conduct Manual MWC02

- Chapter 2 Work Control - Revision 8

~ \O Page 17 4.2 Work Request Preparation Person Step Action Responsible p.no.r l 4.2.1 Perform a job walkdown and field verification of the problem description identified, as appropriate.

1. If the work can be added to an existing CM Work Request, add the work to the existing Work Request.

4.2.2 Make the following determinations using the CECO database or approved Lead Design Document index (LDDI) and complete any required follow-up actions.

lCMl SOER 83 003 RCV Recommendation 9 to SOER 83-8 states that administrative procedures should clearly i

define how to determine safety classyication and quality control requirementsfor l procurement ofequipment or services andfor control ofmaintenance activities The procedure should be aimed at the working level (requisitioner or initiator) amishould Q notprovidefor resolution ofcorlflicts bernen dgerent source documents. Fermi's Q response (EF2-71769) to this recommendation describes how the requisition and u orL orderprocedures meet this recommendation. No changes were made to either procedure in response to this recommendation.

1. QA Level - Determine the QA Level of the component being worked on.

_ {CMl 93074 DER 93 0010 uns issued due to the discovery while accomplishing simulator DER 93 0010 moddications that a recorder didnot match the purchase order description (LER 93 003). In response to this incident. NPP-M4101 uns revised to state: "where a QA level I component is being added or replaced, add a work step requiringfield verification of equipment nameplate and Pls number against the purchase order. "

a. Where a QA Level I component is being added or replaced, -

add a work step requiring field verification of equipment nameplate and PIS number against the purchase order, CECO and/or EDP.

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Work Control Conduct Manual MWC02 Chapter 2 - Work Control Revision 8 Page 18 lCMl CIRC 60-010 . IE Circ 80-10, Failure to Maintain Environmental Qual $ cation ofEqutpment, directs licemees to enforce adequate administrative controls to provide necessary maintenance procedures toprevent such occurrences. Per NRCInspection Report 84-33, Fermi administrathe controls, includmg the work controlprocedure which im okes the controls to monitor, review and document all aspects ofmaintenance actMiles, ensures that components andparts with environmental qual @ cation requirements are ident$edprior to initiating maintenance actMtles. The NRC concludedthat this item is closed No changes wre made to existing procedures as a result ofthis CIRC.

2. EQ Related Ensure all EQ requirements are met as part of the work instruction.

lCMl

-DER 90-432 This DER uas issued in respome to SOER 90-002-RC3 which recommended that plant procedures include guidance on maintaining cleanliness ofthose systems or areas that could introducefsreign material into the reactor core orfuelpool during maintenance or mod $ cation activities. The wnclusion reached, per the DER, was that existing procedures provide reasonable assurance thatforeign material will not be introduced into the RPl'during normalrefueling activities. Noprocedure changes were made in response to tists DER.

O d 3. Clean Class / Zone Determine whether or not the work involves

. housekeeping, system entry requirements, or ifliquid waste may be generated (refer to MMA10, " Foreign Material Exclusion

- (FME/ Plant Housekeeping").

lCMl 91034 in response to violation 90-017-03, " improper implementation ofMaterial DER 91-0021 Accountability around the Spent Fuel Pool", NPP-PSI-Of was revisedfor tool control and accountability - Rev; 6. step 6.1.3.4.B uns added to state that instructionsfor tool control over an open reactor vessel or spentfuelpool needs to be determined u hen work involves housekeeping or system entry requirements.

a. When work is to be performed over an open reactor vessel or spent fuel pool, provide instructions to establish tool control.

b. When a system breach occurs (such as removing a bonnet or valve) on systems connected to the Reactor Vessel or systems which connect to these systems add the following statement just before the step in which system breach occurs:

" Ensure that foreign material does not enter the system.

Foreign material could find its way to the reactor core where it can damage fuel."

Work Control Conduct Manual MWC02 Chapter 2 Work Control Revision 8 Page 19 lCMl 07944 in order to controlfuture heavy loads to be handled over or near spentfuel or required safe shutdown equipment, theprocedures governing the operation ofthe reactor buildmg crane, monorails, andportable hoists willrequire the guidelines of NUREG 0612 to be invoked by either spec @c maintenance procedures or by attachment to maintenance orders / work orders prior to movement ofheasy loads in these areas.

4. Heavy Leads / Rigging - Determine whether or not a Load Handling Form and/or Rigging Approval Form is required.

Include required forms in Work Request (refer to MMA07,

" Hoisting, Rigging and Load Handling").

5, Installation of Freeze Plugs - If freeze plugs are required, ensure requirements of 35.000.233," Installation of Freeze Plugs," are met.

l lCM]

AfD 043 RI'l in response to AfD 43 79, Hydrogen Ignition Design Considerationsfor BWR Ofgas Systems per EF2-66783, the evaluation conducted by Fermi determined that Fermi l

uns in compliance with the criteria and no actions utre required The only criteria related to procedures was B7 which states that maintenance or testing shouldnot be p performed on portions ofthe ofgas system during operation, unless these portions are tQ separatedfrom the process stream by either double isolation valves with air pressure betneen, or a single isolation valve with continuous airpurge on the process side of Ihe valve, Fermi's respome to this criteria states that existing Maintenance andSafety procedures comply with this criteria No procedures were revised in response to this AfD.

NOTE S2 028 in response to IE Note 82 28 Hydrogen Explosion While Grinding in the l'icinity of Drained and Open Reacnor Coolant System. Fermistated (EF2-72142) that procedure 12.000,14 requires: (1) a grinding. cutting and weldmg permit for orn. cutting.

weldmg and'or grinding operation in areas not ident@ed by the maintenance engineer as a permanent maintenance area, and (2) where cutting, uviding or grindmg is to be performed on pipelines, and'or vessels uhich may containflammable vapors, gases or liquids purging ,sith air or CO2 is required These requirements uvre deemed suficient to address the concerm ofthe IE Notice and no changes usre made to the existing procedures.

6. Welding Permit - Determine whether or not burning, welding, grinding, or cutting is to be performed on the component.

a. Obtain weld papers and ensure that Welding Engineer review is required on the Work Request.

b. - Include a Burning, Grinding, Cutting and Welding Permit in accordance with MOP 11, " Fire Protection".

(

, ,l q Work Control Conduct Manual MWC02 Chapter 2 - Work Control Revision 8 Page 20 7; Scaffoldiing - Determine if scaffolding is required for the job.

When required, initiate a scafTolding request.

[CM] _ ,

DLR b&2l13 in resporue to th.s DER that uns issued due to a concern with secondary containment integrity, the wark controlprocedure uns revisedto addspecific requirements to evaluate seconda y containment integrity in the work planning process.

8. Secondary Containment - Determine whether or not the work activity will breach secondary containment integrity,

a. Consider a secondary containment concern to exist if the work:

1) Affects the structured integrity of the Reactor Building including doors, walls, ceilings, and floors (see Secondary Containment Outline Drawing SM721-2319).

2) Affects an electrical or mechanical Reactor Building - '

penetration (see Drawings 4A721-3895 through 4390).

3) Affects a component (for example, piping, valve, pump, etc.) associated with a Reactor Building penetration (that is, removing bonnet or valve associated with piping which penetrates the Reactor Building). (See 23.428 " Secondary Containment Airlocks and Penetrations").

4) Affects a Reactor Building airlock.

lCMl 91014 in response to NRC inspection item 90-017-01 on the use ofcaulking onfloor plugs to DER 91-0023 maintain secondary containment integrity, NPP-PSI-01 was revised (Rev 6) to require use ofappro xd dr.1wingsfor application ofcaulking when sealing secondary containment bourufaries.

b. Seccendary Containment equipment hatches, shield block walls and Control Center HVAC duct work, etc., require sealant caulking applied per approved drawings. Specify in work package, when applicable.

b

9. Tech Spec - Evaluate the work for Tech Spec applicability.

Work Control Conduct Manual MWC02 Chapter 2 - Work Control Resion 8 V Page 21

10. Repetitive Work Evaluation Form Review component corrective maintenance work history. If three or more corrective maintenance Work Requests (similar in job scope) have been performed on this component in the past three years, complete a Repetitive Work Evaluation Form'(Form MWC02002).

I1. RP Review - If work will be performed in a Radiologically Retricted Area (RRA) of Fermi 1 or Fermi 2, or any radiograph for welding, obtain a review from Radiation Protection.

lCMj DER NP-84-020 This DER uns issued due to use ofa maintenance procedure without review and approval of the ISI Engineer and the ANilfor the identification of witness and hold points. As a result, the administrativeprocedure was revisedto includefeatures which will result in work orders being reviewedfor ASAfE code applicability and address the processing of work orders which invoke QA Level 1and11 code class A. B. C, and D+

requirements.

12. ISI/ASME Review . Determine whether or not the work will involve hj in Service Inspection (ISI) components or ifit is within ISI boundaries, including ASME Section XI, primarily ASME Section 111, ANSI B31.7 and B31.lD+ constructed systems. Additionally, consider components on plant systems Cl 103, El1, E21, E41, E51, l_

G33, P33, P34, T46, T4804 and T50 as ISI and ine'uded in the plant leakage reduction program,

n. If work is ISI/ASME related, obtain a review from in Service inspection / Performance Evaluation Program (ISI/ PEP).

b. If repair or replacement of ASME parts is required, prepare ASME Section XI Repair / Replacement Program before installation (refer to MES30, " Repair and Replacement Program").

c. Verify Work Requests for 1.LRT Valves include a copy of the SPF and surveillance indicating the LLRT failure.

(v

Work Control Conduct Manual MWC02 Chapter 2 - Work Control Revision 8 Page 22 lCMl SER 64 04V SER 84-04V descrsbes two separate events where improperly remsembled RHR testable check valves coupled with inadequatepost maintenance testing resultedin degradedsystem operation. INPO commentedthat improvedpost-maintenance quality control would have prevented the events and that localleak rate testing would have detected valve problems. Fermi's response (EF2-71770) stated that " based on maintenance andPN 21 Work Orderprocessingprocedures. QC and ANil onspections. andpost maintenance testing (includmg localleak rate testing where required), Nuclear Productionfeels that calstingprocedures at Fermi 2 minimte the possibility ofoccurrences similar Ic those described in SERs 49-84 and 68-84 and that no change is necessary."

SER 84 068 SER 84-068 describes an ennt where the lowpressure core spray (CS) nstem piping was pressuruedto near reactor pressure while performing aperformance tcst. INPO commented thatpost-maintenance testing was inadequate to detect errors. Fermi's response (EF2 7)770) stated that " based on maintenance and PN 21 Work Order processing procedures, QCandANilinspections, andpost maintenance testing (including localleal rate testing where required), Nuclear Productionfeels that existingprocedures at Fermi 2 minimke thepossibility ofoccurrences similar to those described in SERs 49-84 and 68-84 and that no change is necessary. "

d. Verify Work Requests have a sign-off step for ISI indicating the valve has failed the LLRT and can be disassembled and p)

Egi repaired.

90429 Per NRC 90-OH9, Alamtenance assumed responstbthryfrom PQAfor mcorporating QC holdpoints in work packages.

13. QA Hold Points - Determine whether work performance involves Q1 or Q1M components. If Q1, QlM or ASME components are involved, refer to Hold Point Matrix or the EDP to ensure applicable QA Hold Points are in the implementing procedure, or if not, establish them in the Work Request (refer to MQA05

" Inspections")

14. Part Requirements - Stock Cc3e - Determine required parts to the extent possible,

a. Verify required material for the job is available and requisition it with a Requisition on Stores (ROS). If not available, requisition the material through the Purchase Requisition Process.

b. When notified by the warehouse, verify the correct material ordered for the job has been staged.

n

Work Control Conduct Manual MWC02 6 Chapter 2-WorkControl Revision 8 Page 23

15. Document Type Consult the following documents as necessary to prepare the Work Package:

a. ' - Technical Manuals (Vendor Manuals) and drawings (reviewed forlatest revision)

b. Technical Procedures including Planning and Preparation Sheets

c. Spare Parts Listings

d. Stock Numbers

c. Engineering Change Documents (ECRs)

16. Job Instructions - Determine what job instructions will be necessary to complete the work and which work groups will

! perform the steps, lCMl

!  % 91360 Per DER 91 091 V. Fermi 2 assessed current practsces, using NUAlt RC 91-06 s "Guidelinesfor Industry Actions to Assess Shutda'm Afanagement " improvements adopted as a result ofthe assessment included revision of the work controlprocedure to require appropriate precautionsfor activities that may impact RCS inventory to fully meet this guidelines.

a. For activities that have the potential for draining the reactor vessel, clearly stipulate the initial plant conditions and include appropriate warnings and precautions,

b. Provide specific safety cautions and job notes, where applicable,

c. For WRIFs for failed surveillances, include SPF and the section of the surveillance indicating the faihtre attached when submitted to the NSS.

O

n, Work Control Conduct Manual MWC02

), Chapter 2 Work Control Revision 8

-(w /.

- Page 24 ICMl ._ _

DLR 93 0336 in response to this DER uhich um issueddue toplant trarutent andpersonnelimuries resultingfrom personneldeviatingfrom established uark plans andsequences, the wari controlprxedure was revised to more clearly identyy the intended expectations for work packages. The revision includedprohibiting the use ofNSS holdpoints and requires separate work requests ifthis prohibition can 't be met.

d. Do not use Operations (NSS) HOLD POINTS in the Work Requests. Write separate Work Requests for steps that raust be completed without using Operations (NSS) HOLD POINTS.

- lCM l -

DER 93 0336 in response to this DER wh:ch was issued due toplant transient andpersonnelinjuries resultingfrom personnel deviatingfrom established work plans and sequences, the work controlprocedure was revisedto more clearly identify the intendedexpectations for wark packages. The revision inct dedprohibiting the use ofop*n ended troubicshooting steps.

1

e. For troubleshooting Work Requests:

0

1) Use troubleshooting steps to establish the work boundaries, including potential repairs if known.

2) Do not use open ended statements.

3) After completing necessary troubleshooting steps and identifying the problem, stop all work until the Work

- Request is reviewed by Operations / Work Group Supervisor for possible protection requirements or revision.

Work Control Conduct Manual MWC02 f Chapter 2 Work Control ,

- Revision 8 Page 25 lCM[

DLR V0 0564 . ThU DER uas tssued to track the evaluation ofSER 9016 Point Bindmg of .

SER 90-16 Emergency Diesel Generator hietering Rods,for applicability to Fermi. In response to this evaluation, NPP PSI 01 was revhed(Rev. 3) to include the statement: "When painting ofdiesci engines, compressors, pumps, etc., is required, the Planner shall include a step in the work instructions to require the klaintenance Superrhor to conduct a pre-job briefing to advhepainters against any linkages, pivot points. valve stems, m$tering rods or am. mechanical controlfunctions. "

NOTE 9146 Thh DEX was issued to ensure the concerns ofNRC NO1E 91-46 Degradation of DER 910644 Emergenn Diesel Generator Fuel Oil Deltvery Systems, urre addressedadequardy at Termi 2. The evaluator determinedthat the concerns ofthis notice werepreviously revicurd and dispositioned by DERs 90-0364 and 88 1700. No changes were made to

.RP At4101 as a result ofthis DER or Note.

f, When painting of diesel engines, compressors, pumps, etc., is required, include a step in the work instructions to require the Supervisor to conduct a pre job briefing to advise painters against any linkages, pivot points, valve stems, metering rods L or any mechanical control functions A%Q g. - Evaluate procedure use NUREG-0977 Relative to the A TWS Events at Salem Generating Station (Generic Letter 83 16). Due to a concern with how DECO corfrms that the OER program classification and identi(y includes means offeedback by which DECO can be assured ofreceiving oil GE special instructions.AllSC Technical Bulluins (SILs) applicable to Fermi 2, the NRC requested clar01 cation of 32 SUP 1 DECO's response (Task stem 2.1, Part 2) to Generic Letter 83-16. In their respanse (IG-87 0070, Af1SC 032 Sup 1), Fermi statedthat, as defined by Procedure ISEG 3.1, External Operating Experience Review, assurance that all applicable SILs have been received is determinedby identfying whether am omissions exist beruven a GE master index andSils received ISEG 3.1 was superseded by FIP-cal-Ol(AfLSO2). This issue also addressedpost maintenance operability testing ofsafety related components.

17. Post Maintenance Testing - Determine Post Maintenance Testing requirements (refer to MMA11, " Post Ma'mtenance Testing Guidelines") Ensure appropriate procedures are identified.

a. When a sub-package is generated, specify PMT in each sub-package to ensure the PMT is completed in the correct sequence.

18. Temp Mod - For work involving a Temporary Modification, refer

.to MES12, " Performing Temporary Modifications". q O a

Work Control Conduct Manual MWC02 Chapter 2 Work Control Revision 8

-v Page 26 c

[CMl DER 69-1170 RA C15 Items relating to Fire Protection not on RAC15 lost, Alanyprocedures were identfedas containing an element (s) pertaining to the implementation ofthefire protectionprogram.- A commitment was made "to contact thefire protection specialist and'or thefireprotection engineerfor clar$ cation or assistance as necessary" when changes are made to ensure that nofire protection program commitments are changed or deleted

19. Fire Protection - Determine whether or not Fire Protection Requirements exist for the Work Request (refer to MOP 11, " Fire Protection").

lCMl AfD 037 in response to AfD 037, Hydrogen Accumulation Potentialin Non-Ofgas Area of BWR Plants. Fermi stated in their evaluation (EF2 72231) that all maintenance activities at Fermi 2 are revieued and controlled in accordance :..t ." procedure 12.000.13 and that the NSS or designee review the work order to ensure that the requirementsfor the corfned space entryprocedure are also met. No change to 12.000.13 uhich was subsequently superseded by NPP hu l 01 was made as a result ofthe review afIhis AfD.

SER 83 001 This event discusses the ha:ards associated with gaseous intrusion into the dryuell and identfes spec @c examples. Fermistatedthat i2.000.14. "IndustrialHa ards l Awareness"contains specifc requirements and responsibilities associated with the use l ofha:ardous compressedgases. entry into enclosedspaces, and atmospheric l

monitoring Properlyimplemented. theseproceduralrequirements shouldprevent events similar to those described in the subject SERfrom occurring at Fermi 2. No procedure changes were made in response to this SER. NPP-hU101 superseded i2.000.14.

20. Confined Space - Determine whether or not the work requires

[ entry into a confined space,

a. Make note of the requirement in the work instruction (refer to the Fermi 2 Safety Handbook).

21. Check Valve - Include a Check Valve Data Sheet in the package (refer to 35.000.232, " Valve Disassembly / Reassembly and Rework").

22. Insulation - Determine whether or not insulation needs removal and/or replacement, initiate an insulation request.

O

Work Control Conduct Manual MWC02 Chapter 2. Work Control Revision 8

O Page 27 lCMl NOTE 84 037 in response to Notice 64 37, Use ofLttsedLeads andJumpers during maintenance, Fermi determined that existing design andprocedures adequately addressed the concerns expressedin the NOTE No changes w.m made to existingprocedures in respome to the NOTE

! 23. Interim Alteration Checklist (IAC)- Determine whether or not an Interim Alteration Checklist is required (refer to MMA06, Interim Alteration of Electrical Circuitry), if use ofjumpers is required, refer to MOP 14, Jumper Control.

24. Relay Setting Record Sheet - Determine whether or not a Relay Record Setting Sheet is required.

[CMl DER 89-0766 in response to this DER which was issued due to a violatton of torquing requirements, 89363 the procedure us revisedto state when torquing requirements must be speciped and 89409 to list torquing as one ofthe specific requirements to be considered by ti.e planner in preparing a work package

(-

V

25. Torquing - If specific torquing requirements can be determined, include torquing requirements in the work instructions.

O V

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.v,- ,o e 4 Work Control Conduct Manual MWC02 r Chapter 2 - Work Control ~ Revision 8

-( . Page 28

. lCMl NOTE 83 079 in response to Notice 83 079, inadequate Communications between Maintenance.

Operations andSecurity, Ihe wark controlprocedure was revisedto caution against the inadvertent breach ofa vital security barrier with reference to the Security administrativeprocedurefor specific requirements to be observed (ref. RC SE-86-03631 SOER 82 010-RC2 Recommendation 2 ofSOER 82 010 stated that ofafire barrier isfound to be non-functional, a continuousfire watch should be posted on at least one side ofthe afected barrier. Fermi 2 concurred with this recommendation and stated (EF2-68236) that existing programs were in place to implement the recommendations as required by TechnicalSpecification 3. 7.8a which callsfor afire watch to be in place or automatic fire detection to be in service. No changes sere made to NPP-M41 01 in response to this SOER.

SOER 82-010-RC7 Recommendation 7 ofSOER 82-010 states that mamtenanceprocedures that necessitate breaching barrier integrity during the course of wrk should specifically require the reinstatement ofthe afected barrierfunctions as part of their work close. -

out requirements. Fermt 2 concurred with this recommendation andstated (EF2-68236) that existingprograms wre in place to implement this recommendation No l revisions to NPP-M4101 nre made in response to this SOER. Per EF2 61044.4, response in EF2 68236 wasjudged not acceptable and direction was made to

" incorporate in the appropriate procedure (s) an explicit statement requiring reinstallation ofa fire stop where one has been breached -

' O 26. Barriers - Determine whether or not the work will affect fire, air (pressure), water or security barriers (refer to 35.000.242, " Barrier Identification / Classification"). . If so, include a Barrier Work Request in the work package.

DER 91-0337 Per DER 91 0337, in response to inadequate contractor control of a telephone company employee who uas trenching on DECO property, NPP-M4101 was revised to require the work planner to refer to 33. CON.001for work requiring excavation or back1Illing.

27. Excavation, Backfill or Compacting - Determine whether or not the work will require excavation, backfilling or compacting (refer to 3'. CON.001, " Excavation and Backfill Placement Releases"),

a. If pumping is required, include statement to obtain a pumping permit (refer to MCE06, "Non-Radiological Environmental Protection").

O

.s .

', e Work Control Conduct Manual MWC02 Chapter 2 - Work Control Revision 8 Page 29

[CMl DER 891989 in response to thss DER and DERs 891062 and 1068, the work controlprocedures DER 891062 mere upgraded to provHe instructions!guidancefor the identification ofplant DER 891068 conditions, wark sequence ofoperations, andprerequisites/ precautions (e g , " HOT" 89346 leads) to be aware ofwhen planning unrk.

94088 in response to NOV 93-022 01, the work controlprocedure was revised to require a licensed operator to review and approve the impact statement.

DER 93-0356 in response to this DER uhich was issued due to plant transient andpersonnel sqjuries resultingfrom personnel deviatingfrom established work plans andsequences, the uork controlprocedure was revised to more clearly ident# the intended expectations for uvrk packages. The revision sncludeddefining plant impact codes andrequiring detail ofsysten' component impacts; requiring documentation ofspecific plant'systen! component conditions necessaryfor uvrk; requiring documentation of the developing or revising ofimpact statemets as well as licensed operator review of smpact statements.

l NOTE (1): Impact Statements are not required for Work R.equests containing shop work only.

NOTE (2): Only the sections deemed necessary by a Licensed Operator need be completed, O

V 28, Plant Impact Consult with Operations and/or System Engineer as necessary, and determine whether or not the system / component needs to be drained, isolated, de-energized, etc or what other systems will be affected by the work. Complete the Impact Statement sections as necessary:

a. Impact Code - Indicate the applicable Impact Code as defined below:

v No Outage (NO) - Work can be performed with the component / system in service Component Outage (CO) -Components identified in the Work Request shall be removed from service to allow the work to be performed.

System Outage (SO) - System identified in the Work Request shall be removed from service to allow the work to be performed.

O G

Work Control Conduct Manual MWC02 g Chapter 2 - Work Control Revision 8 ij Page 30 lCMl SER 83-076 in response to SER 83 076, instrument Reference kg failure. Fermt stated (EF2Y~

72467) in response to recommendation N 5 (identification ofcommon reference legs is needed "inJob planning by inclusion in the calibrationpackage. Vapplicable, and work outhorization provided to operations") that the work controlprocedure as uristen addressed this concern No changes uere made to theprocedure in response to this SER

b. Plant Systems / Components Affected -Identify the plant systems / components to be worked on by noun name and PIS number. Also list any additional plant equipment that will be affected by performance of the work such as connecting or interfacing systems /compements that will be removed from service or realigned to allow performance of the work.

Provide brief description of work to be performed.

I

, c. Prohibited Parallel Work - Identify plant i

systems / components on which NO maintenance activities including surveillances shall be performed during performance of the Work Request. This will include reh.ted

( systems identified by a Tech Spec Limiting Condition for Operation (LCO), work in the opposite division, work on redundant instrument channels, etc.

d. Required Plant and System / Component Conditions -

Identify the plant condition in which the work is required to be performed by checking the appropriate block. Describe any special system / component status requirements for performance of the work,

e. Special Requirements Prior to Equipment Tagout -

Identify any special requirements, such as run a fan for 20 minutesjust prior to equipment tagout for lubrication, provide temporary power or place standby equipment in service,

f. Print name and date the Impact Statement on the second page. If the Impact Statement is revised, make sure the person making the revision prints name and dates the second page in the location provided.

Work Control Conduct Manual MWC02 p Chapter 2 Work Centrol Revision 8 i U_ Page 31 lCMl DER 93 0612 in response to this DER which uns issued due to an incorrectplug installatoon, the procedure was revised to address how pluggedinstruments are to be handled

29. Control Room Work Request - If work is to be performed in the Control Room, add a precaution in the Work Request prohibiting the use of any test equipment, tools or power cords in any dedicated 120V AC power supply receptacle,

a. When installing components which plug into the dedicated 120V AC power supply receptacles, ensure the plug / receptacles are controlled in accordance with MMA06,

" Interim Alteration of Electrical Circuitry".

30. EDP/TSR Work Requests - For Work Requests implementing EDPsffSRs:

lCMl 90163 The procedure was revised to allow " work at risk ". This means maintenance work

& can continueprior to issuance ofan approveddesign change. Implementation impact is evaluated and afected components / systems cannot be returned to service or declared operable until Ihe design change paper is issued and work performed is reconciled to the approved destgn change paper.

NOTE: Work Requests implementing ECRs/fSRs issued as Approved At Risk and modifications that contain an Engineering Operability Constraint (EOC) may be released for work but cannot be accepted for return to service by the NSS. This prevents equipment from being -

returned to service until the work package is updated to show that required modification document revisions are issued and work performed is reconciled to an approved design change document.

lCMl 93166 in response to LER 93-003, TechnicalSpecoficarson instrument Poueredfrom 93167 Improper Electrical Outlet, the work controlprocedure uns revised to require ajoint walk down ofmodifications before the afectedsystems are returned to service. This is accomplished with a turnover checklist

a. For TSR Mod /EDP Work Requests, add a step in the Work Request to have the Maintenance Supervisor or Modification Field Engineer contact the TSR/EDP owner to contact the System Engineer and NSS/ delegate for field verification of

(}

k the final installation. Also include a sign-off for the Maintenance Supervisor or Modification Field Engineer to

)

, f ; , ',- ,

Work Control Conduct Manual . MWC02 -

p: Chapter 2. Work Control Revision 8 -

G -

Page 32 verify the completion of the Tumover Checklist (MES20,

" Implementation of Modifications").- Furthermore, this step is to be placed after completion of work and before system

- testing.

b. If the Work Request implements a modification being made in accordance with a TSREDP dispositioned Approved at -

Risk, provide a final step and signoff to verify the Work -

- Request i_s reconciled to the approved TSR/EDP prior to -

returning the equipment to service, i

c. When installing new equipment, add a step in the Work -

l Request to remove all shipping plugs, bars, stiffeners, etc.

.before testing and placing equipment in service (see Hold Point Matrix).

d. Contact TSREDP owner to resolve discrepancies that may exist between testing procedures specified in the TSREDP 1 versus the actual procedures to be used in the performance of

~

the Work Request.

l 89627 in response to SSOM) item 89-200-03, inadequacies in post-modification testmg -

(Ph(T). theprocedure was revisedto add a step to Ph!T instructionsfor the EDP owner to signfor wrification ofthe post maintenance testing and DCA T.

c. For TSR Mod /TSR Setpoint changeEDP Work Requests, add a step in the PMT Instructions of the Work Request for

- the TSREDP Owner to sign ofTfor verification of post maintenance testing and specified Design Change Acceptance Test (DCAT).

f.

To expedite field changes during the implementation of an

- EDP, an At Risk ECR may be prepared to include, at a minimum, an ECR' cover sheet with a brief description of the change, the preparer's signature and the Modification .

. Owner's (or delegate's) verbal or written approval,

g. For TSR ModEDP Work Requests, include a copy of the Tumover Checklist from MES20, " Implementation of Modifications".

L

f. 3 ,;

Work Control Conduct Manual- MWC02 Chapter 2 WorkControl Revision 8 Page 33

h. For TSR Mod /EDP Work Requests, obtain a Modification impact Statement from MES20, " Implementation of Modifications",

i. For TSR ModffSR Setpoint change /EDP Work Requests, have the Work Request reviewed by the TSR/EDP Ownet j, When an EDP Work Request is begun during an outage but not completed, and it must be completed during subsequent outages, deactivate Work Request after each outage until complete.

lCMl DER 93 0:52 in resporue to this DER which was assueddue to the discovery ofloose terminal board 93172 coversfound on EQ transmitters, the work controlprocedure ws revised to (1) .

require the work package planner to clearly identify each sub-package and its scope on the original work request andto clearly delineate the requiredactivities in the sub.

packages and(2) require an as-built walk down with mods /maint., the EDP owner and .

Ops.

1 93l91 At the July 1, I993 ergforcement cortference, management committed to (I) ajoint 93I93 engineering! implementing group' operations walkdown ofallfield complete

-Q 1

& modifications will be done, and (2) allplant modifications will beformally turned over to the operations organisation. A turnover checklist willbe utilised The second

' commitment ws implemented in FIP-CAfI l&'AfES20. Thefirst commitment is a duplicate ofRAC15 sterv 93193

1) Make sure As Built configurations are walked down by the EDP owner, System Engineer, Maintenance Supenisor/ Modification Field Engineer, and the NSS/ delegate in accordance with MES20,

" Implementation of Modifications".

2) Before reactivating the Work Request, have Maintenance Supenisor/ Modification Field Engineer and the EDP owner review the Work Request and EDP, and make any necessary changes, to ensure proper i nplementation. Document this review in the Work Request and have both individuals sign.

k. Injection sealing ofleaks on plant systems or components shall require a TSR.

Work Control Conduct Manual MWC02 p Chapter 2. Work Control Revision 8 h Page 34 lcMl 90)43 in response to NOV 69-036-01, improper tratallation ofa wide range reactor water level transmitter, the procedure was revised to requirefor uvrk involving ieplacement or installation ofa dderentialpressure type transmitter (QM or iM only) that on independent verthcation is then performed

31. Independent Verification Ensure Independent Verincation requirements have been met in accordance with MOP 02, independent Verification.

32. Plant Decommissioning Records -If the Work Request implements an EDP in the RRA, print or stamp

" DECOMMISSIONING RECORD"in the upper right comer of the Work Request (refer to 10CFR50.75.g.2).

lm.nn., l 4.2.3 Enter Work Request information into WST.

1. For modiScations, ensure the ModiGeation number is entered into the Related Documents Geld.

n U 4.2.4 Obtain reviews required by Work Preparation part of the Work Request.

4.2.5 Consult with Radiation Protection for specine radiation protection requirements.

Manner l 4.2.6 Send Woik request to Work Group Supervisor for walkdown and review.

4.2.7 P. ovide the Work Request Impact Statement and cover sheet to Operations.

we o,oup supervisor 4.2.8 - Review Work Request package.

1. Review Job Instructions ensuring they are clear and address the problem description.

2. Review PMT requirements, ensuring PMT requirements are consistent with work scope, plant conditions and PMT guidelines (if problem exists with PMT, contact General Supervisor).

3. Perform walkdown of Work Request.

( 4. Verify parts staged are adequate.

5. Change status to " Ready to Work."

a .. .

Work Control Conduct Manual MWC02 Chapter 2 Work Control Revision 8 h

b Pr.ge 35

)

4.3 Work Authorization Person Step Action Responsible l

NOTE: Work Requests for shop work do not require Operations review or NSS approval prior to work and will be delivered to the responsible Work Group.

lCMl 06367 in response to identified wakness (IE 65 044 04, lack ofposans communicanoru bernen Security and Alaintenance, Fermi agreed to implement a program to assure Nuclear Security is notifiedprior to maintenance actMties which may adversely afect Securin.

Work Group 4.3.I If Work is SCCurity related, have Nuclear Security Shift Supenisor sup. Mao' (NSSS) review Work Request and initiate appropriate compensatory measures, then sign and date on Work Authorization part of Work Request. This acknowledges security has taken appropriate actions and l g is ready for the NSS to authorize the work.

\O 4.3.2 If unique protective tagging is needed, complete the Protective Tagging Request in accordance with MOP 12, ' Tagging and Protective Barrier System".

I a.m.uon . 4.3.3 If required, record specific Radiation Work Permit (RWP) number on -

ProkcNon Work Authorization part of Work Request and ensure all As Low As Reasonably Achievable (ALARA) reviews have been completed when RWP is issued, m

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Work Control Conduct Manual MWC02 Chapter 2. Work Control Revision 8

'O Page 36 lCM]

DLR V3 W36 in response to this DER which was issued due toplant transient andpersonnelinjuries resultingfrom personnel deviatingfrom established work plans andsequences, the work cont olprocedure was revisedto more clearly identify the intendedexpectations for work packages. The revision included requiring the review andapproval ofthe impact statement by a licensed operator.

NOTE: Approval of the impact Statement can be performed by any Senior Reactor Operator (SRO) holding an active or current license.

[ucensar opereror 4.3.4 Identify the Control Room and Radwaste Control Room alarms, l

abnormal indications (for example, indicator / recorder falling upscale, '

downscale or as is), actuations and trips that are expected as a result of the work.

1. Technical Specification Sections - List the Technical l Specification numbers that apply for the plant condition in which l work is required to be performed.

A 2. Actions to Prevent Unwanted Alarms, Indications, Actuations V and Trips - Identify the actions to be taken to prevent unwanted alarms, indications, actuations and trips. Operations makes the final determination of unwanted system / component responses.

k (J

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k. _

l Work Control Conduct Manual MWC02 Chapter 2. Work Control Reviden 8 Page 37 l

-lCMl V1013 in response to non-cited violation WO) 7 W, fatture to inissate a "No protection Record", the work controlprocedure was revised to include a protection sign-ofon the wark requestform andto designate Ihe resec:h tagging eenter supervisor with responsibilityfor determining (fprotection is required wwa cene.i sao. 4.3.5 Review and approve Impact Statement. M approval states the SRO a renr erne agrees with the entire impact Statement and has perfomied an c n=r us independent review of the applicable Technical Specifications.

1. Document Safety Tagging Record and/or LCO number on the Work Request. Document CRIS Dot number on Work Request. If not required, mark the N/A block.

NOTE (1): Equipment shall net be removed from service until the plant conditions nicet that required by the impact Statement.

NOTE (2): Work Requests may contain work steps for Operations (for example, to modify personnel protection).

Q,s f , 4.3.6 Review the Work Request, LCO, impact Statement and Safety Tagging wass Record (STR) When plant conditions meet requirements of fmpact Statement, autho-ize the equipment to be released for maintenance or modification work activities.

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1 Work Control Conduct Manual MWC02 Chapter 2. Work Control Redslom 8 Page 38 ,

4 lCMl 94992 In resporue to NOV V3 022 01, the uora controlprocedure uns revised to ensure that proper plant conditions andprotective taggingfor the total uptk package are estabibhed before the NSS releases a uork package.

DLR V3 0342 in resporue to this DER, the ucrk controlprocedure uns revised to not allowfor the Work Request to be sigrudon untilaffer the ALS h completedandver$edby the NSS DER V3 0666 in resporue to thu DLR, the work controlprocedure was revued to include documentation cfapplicable ALSs on the work request.

NOTE 83 036 in response to JE Notice 83 36, Operabthry ofRequtred A ustliary Equipment, Fermi NOTE 84 42 stated (EF2 72736) that Ihe uvrk orderprocedure: (1) requires the Operations SER 84 42 Engineer (or designer) to Indicate ifan item h Technical Spec $ cation related, and(2) '

the Sh@ Superrhor h required to sign Ihe nork order prior to releasing Ihe uork order, This uns determinedto be sufficient to truure that equipment uhose operabihty h required to support the operation ofsqfety relatedsystems b identfed. No changes to the uvrk order procedure urre made in resporue to this NOTE.

SER 63 066 In response to SLR 66 83, Ftre in Atain Generator Lxester Housing. Inspections and a prnrntive maintenance laskfor the e,nciter/ collector rings andbrushes urre implemented The Fermi 2 response aho stated (EF2 72468) "Afaintenancepersonnel keep Ihe Control Room personnelirgformed ofongoing uvrk activity Ihvough Ihe use of a uvrk order signed on through the Control Roompersonnel... " No changes utre made to the uvrk controlprocedure in response to this SER SLR 64 042 in resporue to IE Notsce 83 36, Operabthty ofRequired Antiliary Equipment, Fermt 0 NOTE 83 36 stated (EF2 72736) that the uork orderprocedure: (1) r* quires the Operations

%) NOTE 84 42 Engineer (or designee) to indicate tfan item is TechnicalSpec$ cation related, and(2) the Sh$ Supen bor is required to sign the nork order prior to releasing the work order. This uas determined to be suficient to ensure that equipment whose operabihtv is required to support the operation ofsqfety relatedsystems is identWed No changes to the work order procedure urre made in resporue to this NOTE, Per memorandum .

datedJuly 24, I984from R. Ratrick to W. Adams the response toIENotice 83 36 (OP. 84103) uns deemedsuficient to also close Notice 84 42 andSER 84 42 mhich describe similar events.

SOER 64 006.RC4 in response to recommendation N 4 (Work on turbine control andprotection system components should not be allowed while the turbine is in service without the spec $c approval by senior maintenance and operations group management. When such nork h required, activities should be carefullyplanned and controlled to minimi:e errors),

Fermistated(EF2 71434) that "the controls inherent in Procedure 12.00013 ensure that all work, including work on the turbine control andprotection system, h approved and released by operations management. " 12,000.13 uns supersededbyNPP AM!.

Of. No changes usre made to the uork controlprocedure h resporue to Ihis recommendation DER 881434 This DER was hsued to track the response to lnspection Report 880)2 04, Open hem onpage 10, where the NRCperceivedinadequacies in the control ofthe NSS Current Work Request Notebook. The work controlprocedure was revised to reflect NSS responsibthry during sign on ofAfinor and Alqlor uork requests and to reflect NSS resporuibility during work request closure.

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Work Control Conduet Manual MWC02 Chapter 2. Work Control O Revision 8 Page 39 NOTE: The signature of the Nuclear Shift Supervisor is required in order to begin the maintenance. This signature indicates the equipment is properly aligned to support maintenance, tags have been placed according to the STR, and plant conditions meet the requirements of the impact statement. When the NSS signs the Work Request, the NSS is releasing the equipment to Maintenance allowing them to complete all work steps. The NSS cannot release a Work Request to do only selected work steps.

I N,*o",f 4.3.7 After the equipment is removed from service if required, sign on the N4ss- Work Request, n rca r.,,in, 4.3.8 Notify the Work Group that the Work Request has been released by the center uso NSS.

4.4 Work Performance Person Step Action g Responsible NOTE: The Work Group Supervisor should make visits to thejob site. Fiity percent of the Work Group Supervisor's time should be spent in the field, work Group 4.4.1 Review work package, ensuring it is complete, including all information sup.mi.*'

and documentation necessary to safely and efficiently complete the work.

work omup 4.4.2 If possible,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to starting work, ensure RWPs are in place as sup wisor needed to support the activity. Read RWP to ensure all aspects ofjob are covered.

4.4.3 Ensure required documents are the latest revision and are controlled.

work o up 4.4.4 Ensure special tools have been identified and are available, servisor 4.4.5 Ensure other involved groups (Radiction Protection, Operations, etc.) are aware of the start of work.

4.4.6 Conduct ajob briefing in accordance with the following general guidelines:

V 1. Identify people involved, including name and organization.

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Work Control Conduct Manual MWC02 Chapter 2. Work Control Revision 8 O Page 40

2. Review the planned evolution in sufficient detail to assure understanding by participants.

3. Identify the duties and responsibilities of each person involt ed in the planned evolution.

4. Ensure prerequisites are satisfied (such as procedures are approved, personnel trained / certified). _

5. Ensure proper test equipment is identified and available.

6. Review precautions and limitations and comments of Planner.

I

7. Review any communication requirements, including chain of command and special communications equipment.

8. Ensure participants are familiar with procedures and equipment.

9. Review potential abnonnal occurrences or failures that may occur and discuss and assign recovery actions and responsibilities.

10. Review potential safety hazards, special RWP ALARA considerations and general radiological conditions.

Work Group 4.4.7 Resolve any questions arising during the pre job briefing.

sue.M.or o.,..r. sup m. ors. 4.4.8 Perform the work as follows:

Work Group Supervisor Work Group

1. Ensure the area is well lit and accessible.

2. Ensure the proper parts and tools are being used.

3. Ensure industrial safety requirements are adhered to during performance of the work. Report unsafe conditions to the Work Group Supervisor.

4. Adhere to housekeeping and cleanliness requirements.

O 5. Ensure work is performed within the tagging boundaries, if applicable.

Work Control Conduct Manual MWC02 Cbspier2 Work Control Revislom 8 Page 41 l 6. Review and understand the RWP and work within the limitations imposed by the RWP,if applicable.

7. Perform work in accordance with the instructions provided in the Work Package and ASME Section XI repair / replacement program, ifapplicable.

8. Ensure the original work request package /sub package is located at the work site. Do not take original Work Requests into contaminated areas. Use copies.

[CMl DLR 66 0026

' This DER was issued due to a missed QC Wnness Point. Correcttre action was to DER NP 86 283 urite Standing Order 86 22 (QC K'itness Points) and revise the admin procedure to clartfe OC witness point process.

9. Notify inspection and Surveillance (l&S) and/or other support personnel at each hold point listed in the Work Package. Stop maintenance activity until hold points have been completed and

\

signed off.

10. Stop the maintenance activity and notify the WGS immediately if the following occurs:

a. Activity cannot be completed in accordance with approved procedures.

b. Activity cannot be completed as written in the work package,

c. Drawings required to complete the work are found to be incorrect and those drawings are being used to do the work described in the work package (for example, wiring diagram).

1) Upon job completion, bring discrepancies found in drawings, that are not a hindrance to continuing work safely and properly without first correcting the drawings, to the attention of the Work Group Supervisor.

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i Work Control Conduct Manual MWC02

! Chapter 2. Work Control Revislom 8 Page 42

{

worn aroup 4.4.9 If the work must be continued into the next shill, conduct a shift s w oor tumover meeting with the oncoming Work Group (WO) and Work Group Supervir,or (WOS). Conduct the turnover in accordance with the following general guidelines, if necessary: l

1. Reviewjob status.

2. Identify any evolutions cunently in progress.

3. Review special precautions or concems including RWP requirements.

4. Review upcoming evolutions.

5. Identify any abnormal situations.

6. Review responsibilities of participants.

7. Ensure oncoming crew is aware of procedures, protective tagging, etc. that are in effect and in use on the job.

• d*" ,,s, /,,, 4.4.10 Upon completion of the work:

1. Ensure cleanliness of worksite.

2. Ensure tools and unused materials are returned to designated sto4 age locations.

3. Ensure work is documented in detail, as appropriate, in 11istory Part of Work Request or appropriate procedures, including reference to procedures, materials and test equipment used to complete the work,

a. Initial and date all entries in this section.

4. Review work package for completeness and accuracy.

5. Col'ect and combine any completed sub. packages back into the master Work Package. When all subpackages have been O

O completed and documented in the master Work Package, process the Master Work Package for Closecut and Retum to Service.

Work Control Conduct Manual MWC02 Chapter 2. Work Control Revision 8 Page 43 Iwerearou, l 6. If Work Request identifies additional equipment failures, that could not be completed, or identifies any unusual circumstances, notify Work Group Supervisor to determine if ftuther investigation is required, worn aroup 7. If the Work Request implements an EDP, notify EDP Owner when s w i .'

work package is craft complete.

l lCMl DER 93 02b2 in response to this DER u hich u as issued due to the discovery ofloose terminal board 93172 coversfound on EQ transmitters, the uvrk controlprocedure was revised to (1) require the uvrk package planner to clearly identify each sub-package and its scope on the original uork request and to clearly delineate the required activities in the sub.

t>ackages and(2) require on as built walk down with mods /maint., the EDP ouner and Ops.

9319) At the July 1, I993 ergforcement corlference. management committed to (I) ajoint 93193 engineering! implementing group' operations walldown ofallfield complete 93167 modfcartons will be done, and (2) allplant mod $ cations will beformally turned over to the operations organhatton A turnover checklist willbe utdt:cd The second

ommitment was implementedin FIP Cht! INhfES20. Thefirst commitment is a

\,

duplicate ofRACTSitem 93193 EDP Owner 8. If the Work Regt.est implements an EDP/TSR, walk down the completed modification with the EDP Owner, System Engineer and NSS/ delegate to verify proper implementation of the modification in accordance with MES20, " Implementation of Modifications". Sign and date Work Request to signify the completion of1:..: Modification to Operations tumover checklist.

E 4 Work Control Conduct Manual MWC02 Chapter 2. Work Control i Revision 8 Page 44 4.5 Work Closure Person Step Action Responsibir o.n.w sup**ws. 4.5.1

" * *** * * **' Ifjob specific RWP was issued to perform work, notify Radiation Protection that work is field complete.

IcMI __

07647 in resporue to LER 83 060-01 (NP-86-0133) the uvrk orderprocedure was revisedto require the workforeman to document completion of uvrk items prior to submitting the uvrk order to the NSS.

90427 NRC 90-dII9, Revuton to PQA reviewprocessfor unth requests, states that maintenance willassume responsibihtyfor verffying appropriate sign-ofs have been made and that approvedproccoures and design documents urre used f

Wort Gmup 4.5.2 Perform rCview of Work Request for completion ofjob instructions and r

svP* * *' documentation of work performed.

O O 1. If not already recorded, record As Found Condition and Cause of Failure in History part of Work Request.

2. Verify Job Instructions were completed and signed in Job Instructior.s part of Work Request.

3. Verify work area has been left in acceptable housekeeping condition.

4. If parts are used, list applicable stock code numbers, serial numbers, quantity used, ROSs, or Purchase Orders /RIRs in Parts Requirements part of Work Request.

5. Verify all M&TE used during performance of the Work Request is documented in Section 14 of the Work Request. If none is used, enter the word "None."

6. Verify special tools, scaffolding and M&TE used during the performance of the Work Request are recorded in Tools /M&TE part of Work Request or in the procedures.

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l Work Control Conduet Manual MWC02 Chapter 2. Work Control Revision 8 Page 45

7. Verify all related documents used, such as drawings, vendor j manuals, procedures or Design Change Documents, have been recorded in Related Documents part of Work Request

8. Complete liistory/NPRDS information for all Work Requests i associated with NPRDS reportable components with exception of cancellations.

9. Verify all 1&S Inspection Reports are satisfactory or addressed and enclosed in Work Package.

10. Verify personnel protection has been released in accordance with MOP 12, Tagging and Protective Barrier System.

I 1. If a Work Request Tag was hung on the defective equipment or posted at a room entrance, verify that it has been removed.

Generes supervisors. 4.5.3 worn aroup supervisor Complete Work Request Feedback Form (Form MWC02006), if when ssary, and send to General Supervisor. Send Work Request to Control Room for Return to Service.

[o.n.c., supervisors l4.5.4 Review Work Request Feedback Form and take appropriate action.

lCM] -

DERNP b6 073 in Response to this DLR uhtch uns issued due to testong requirements not completed in a wark package, Ihe procedure uns revised to include a step to review Ihe implementation plan prior to issuing Ihe pacLage to Ihefield by the planner.

4.6 Post Maintenance Testing (PMT)

Person Step Action Responsible

, worn aroup 4.6.1 Review proposed PMT requirements in PMT Instructions part of Work supervisor Request.

1. Verify PMT requirements are still applicable for actual work performed (refer to MMAll, Post Maintenance Testing Guidelines as necessary).

(

Work Control Conduct Manual MWC02 6 Chapter 2. Work Control Revision 8 Page 46

[CMl 07b53 in response to IL 66-028 01, the work controlprocedure was revisedtoprovide additionalguidancefor testing and toprohibit the changing ofpost maintenaroce requirements without the concurrence ofIhe applicable discipline. l

2. If PMT requirements need changing, consult the applicable discipline, then make changes with appropriatejustification. If work will be in the RRA, have RP review changes, then obtain

approvals from appropriate General Supervisor or NSS. ,

NOTE: Work Requests for shop work do not require Operations review prior to closure. .

wort Group 4.6.2 Deliver package to NSS or NSSS if Security equipment is involved.

supervisor nuciest snin sup. 4.6.3 Review Ph1T requirements to determine if requirements for testing meet

$g*** present plant condition.

1. If plant conditions do noi permit performance of PMT as originally requested, contact WGS for resolution.

2. Coordinate changes to PMT with the appropriate General Supervisor, if required, to ensure operability, include the addition or deletion of specified PMT as required.

4.6.4 Coordinate and provide support personnel for PMT.

lCMl 07384 In response to a 1hchnical Spectfication () 6.1.1) violation when the Licenseefailed to maintain containment integrity (IE 83 04011). the work controlprocedure uas revised to require signofofpost maintenance testing (PMD completion.

07646 in response to 1.ER 63 060-01 (NP b6 Ol33), the work orderprocedure was revised to requirepost maintenance or modgfication testing to be completedprior to signing of the work order andfor the person performing the testing to document completion by signature.

worn aroup sup. 4.6.5 Document PMT results on Work Request to indicate acceptable PMT

$ $'8 s"P' , was completed.

Shift Sup

1. If PMT results are unacceptable, document what was unacceptable and return to work group for further evaluation.

l i-

. .s Work Control Conduct Manual MWC02 Chapter 2. Work Control Revislos 8 Page 47

2. For PMTs involving performance of surveillance procedures, place

copies of Surveillance Performance Forms (SPFs)in Work l Package and send original SPFs and completed procedures to the Surveillance Group.

w.,* or,up 4.6.6 If the Work Request was initiated as a result of an EDP, have the EDP swoo' owner sign off steps supplied in the Work Request to signify concurrence with test results.

gg' sns suP- 4.6.7 Complete the following before signing Return to Senice (RTS) shl4 sup authonzation:

. 1. Verify all STRs have been cleared.

2. Verify PMT/DCAT has been performed satisfactorily, if required.

3. Submit Work Request to Nuclear Assistant Shift Supenisor (NASS) to clear LCO Log if required (not applicable if Security).

4. Verify compensatory measures have been cleared (not applicable if Operations).

S. Verify actions required by Work Group up to this point are signed ofras complete and that there are no operability restraints.

6. Submit Work Request to Control Room Nuclear Supenising Operator (NSO) to clear and remove CRIS Dots (Not applicable if Security).

7. Verify work area was left in an acceptable housekeeping condition.

8. Verify red lining is complete, if applicable.

9. Verify all procedures required to be revised are completed.

10. Verify DCAT testing is signed on MIC.

11. Verify Modifications to Operations Turnover Checklist is complete,if applicable.

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Work Control Conduct Manual MWC02 O Chapter 2 Work Control Revision 8 V Page 48

12. If equipment can be retumed to service, sign Retum to Service part of Work Request.

uvener snin sup. 4.6.8 Return Work Request to appropriate General Supervisor for vaulting.

Nucker Aselet ShlR Sup 4,7 Post Work Review l

Person Step Action Responsible l work Group 4.7.I If Work Request is a Preventive Maintenance Work Request, close the supwisor PM Work Request in accordance with MMA03," Preventive Maintenance and Periodic Calibration and Testing".

4.7.2 Obtain appropriate signatures on Post Work Review part of Work Request.

4.7.3 Update WST, as necessary, to reflect any changes made during Work Request processing.

4.7.4 For EDP Work Requests, remove original Modifications implementations Checklist (MIC) from Work Package and forward to MIC Coordinator Place a copy in Work Request.

4.7.5 For EDP Work Requests, make a copy of the Work Request instructions (green sheets) and forward to MIC Coordinator.

4.7.6 Remove original cable pull cards from the package, transmit them to Plant Support Design Group. Place copies in Work Request.

4.7.7 Prepare Work Request for vaulting.

1. Enclose a Nuclear Services Coding Sheet.

2. Ensure Modifications to Operations Tumover Checklist is vaulted with Work Request.

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Work Control Conduct Manual MWC02 Chapter 2.WorkControl O

Revision 8 Page 49 lCMl MISC OlW in response to MISC.ly, Nuclear Power Stattom Plant Atr Systems Review, only a single review response uns in any way relatedto the work controlprocedure, This was in response to Iecommendation G 13 (An operating problem hbtoryfile should be established onplant air systems). This response stated (EF2 69163): "A hhtoryfile h dxelopedfor turnedover systems using informationfom the PN 21 (N'ork Order)

Processing Procedure andthe Deviation and Correcstre Action Procedure. Thus, this requirement will be met u hen the entireplant air system h turned over. No changes or commitments were made to the wora orderprocedure as a result of thh OER.

3. Send Work Request to vault.

lCMl DLRbWobol in response to this DLR which was ist ucd due to wark packoges inadequately preparedfor vaulting, the procedurs uns revhed to state: "Pages on Quality Assurance records being transmitted to the vault to supplement a N'ork Package already in the vault shall be numbered (for example Page i to 10).

NOTE: Number pages on Quality Assurance records being transmitted to the vault to supplement a Work Package already in the vau!t (for example, Page 1 to 10).

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Werk Cc: trol Cc d:et Man:al MWC02

, Chapter 2. Work Control Revision 8 Page 50 O 4.8 Work Request Revisione ,

i NOTE: Changes tojob instructions or PMT are not considered a work package revision unless these changes are made after the package has been released by the NSS. If changes are made to a work package prior to being released by the NSS and after initial approvals have been completed, the package should be resubmitted for approvals. l Person Step Action Responsible wo,* oroup 4.8.)

supervisor, *""*' Determine Whether or not the revision can be categorzied as a minor tevision.  ;

1. Examples of minor revisions include the following:

a. Step sequence changes

b. NA of steps that are obviously not required

c. Additional clarification or subdivision of work instructions

d. Minor additions that do not adversely affect work quality, increase scope, or affect a specified test

e. Correction of typographical errors, misspelled words, or -

incorrect document references, part numbers, or stock numbers

f. Unit of measure conversions (for example, changing 10 ft/lb to 120 idlb of torque)

g. Approved alternate materials d DER Vl 0430 DER 910430 uns issueddue to insuficient tagging ofenergised equipmentfor uvrk that uas caused by revising the work package without requesting protection changes or obtained the required approvals. In resporae to Ihis DER. NPP.M4101 uas revised to read that the Protection Leader / Group Supervisor is responsiblefor revleuing protection.

2. Revisions which are not considered minor include the following:

I a. Plant equipment setpoints

i Work Control Conduet Manual MWC02 6 Chapter 2. Work Control Revislom 8 Page 51

b. Surveillance acceptance criteria

c. Increase / change ofjob r, cope or duration (for example, i package was originally written to repack a valve, but the valve needs to be replaced)

d. ISI or ASME code work

c. Protective boundary changes that require the impact l Statement to be revised.

f. Work Request instructions supplied directly from an Engineering Change Document (EDP, TSR, or Temp Mod) 4.8.2 If the revision meets the criteria for a minor change, make the revision i

and have the General Supervisor / delegate clearly initial and date the change; otherwise, GO TO 4.8.3.

4.8.3 Make Work Request revision adhering to the original determination Os requirements of Section 4.2 and complete the following:

1. If space allows, insert the new step in its sequential order. The step should be numbered with a sumx (for example: a, b, c). If not enough space, note that there is a revision to the work plan and add the steps at the end of the job instructions.

2. If steps are to be deleted, lineout the step on the Work Request and initial and date. Also provide a brief explanation for the deletion.

3. Place revision bars next to all changes.

4. Initial and date the revision bars.

5. If a protection contract is in effect, follow the requirements of MOP 12, Tagging and Protective Barrier System,

6. Perform preliminary review of revision changes to determine whether the problem identified is a System, Structure or Component (SSC) Functional Failure as defined by the Maintenance Rule, if the determination changes the results of the O erisi airevie erta wert aea#est.revisetae arererriate niect

= _ _ _ . _ .' __ _

,= . .

4 4 Work Cuatrol Conduct Manual MWC02 Chapter 2. Work Control Revision 8  ;

Page $2  !

on the WRIF and forward a copy to System Engineering; otherwise, leave it marked as is. t 7.- Document all changes on the Work Request Revision Form (Fonn MWC02001) as follows:

a. List revision date and revision number, ,

~

b. . Provide a brief description and reason for the change.

c. Initial for revision then date.

lCM]

94318 in response to LER 94 003, " Actuation ofIsolation Logic Due to Pouer interruption during logic Mod $ cation. " the work controlprocedure was revised to review the work request impact statement uhen EDP revision and ECRs are issued.

d. Have necessary organizations review the Work Request revision then initial and date for the review This should include a review by Operations of the impact Statement.

ICM]

DER 69 0261 1 hts DER arulDERs 89 0327, .0383, and 0601 were issued due to work requests DER 89 0327 being issued without receiving aproper review. In response. Accountabihn meeting DER 89-0383 89 011 uas held, andactions taken to correct the root cause utre documented One DER 89 0601 oction taken uns to require that work package revistom he attached to thefront ofthe uvrk package.

c. Attach the Work Request Revision Fonn to the front of Work' ,

Request.

lCMl' DER 910430 DER 910430 was issued due to imuficient tagging ofenergized equipmentfor uork .

that was caused by revising the work package without requesting protection changes or obtained the requiredppprovals in tespome to ihis DER, NPP M41 Ol was revised to read that the Protection hader/ Group Supervisor is responsiblefor reviewing protection u ,,,,,nm 8. Ensure all work authorization reviews and requirements are met as --  ;

superwoor described in Section 4.3, then initial and date the Work Request Revision Form. i 1  !

8L--Tr--1--'-'We't *M- P-tP-*4 m--**-M- -t='-*+t=M- --?vTMW*r7Y 8--Fh= T ve-h h "M F a'='Y'r'u'-- T' **t'*If MW'T

Work Control Conduct Manual MWC02

Chapter 2. Work Control Revision 8 Page 53 4.9 Work Request Cancellation Person Step Action Responsible NOTE

This section shall only be performed for Work Requests or Minor Maintenance Forms where no work has been performed in the field.

lae***r l 4.9.1 Cancel Work Requests as follows:

1. Sign, date and enter, reason for cancellation on WRIF or in WST.

2. Send WRIF/WRT to Maintenence Supervisor, Planners, Schedulces or NSS.

3. Retnr.e the WRT from equipment.

4. To cancel Work Requests that have been signed on by the NSS:

a. Sign, date and enter reason for cancellation on WRIF or Work Package,

b. Notify Control Room Clerk to delete NSS sign on dater in WST. Remove Cris Dot and cancel other unnecessary related documents.

c. Notify RP to terminate RWP.

d. If PM Work Request, close it in accordance with MMA03,

c. Forward to Maintance Supervisor, Planners, Schedulers or NSS, menner, sche **r. 4.9.2 Perform the following:

NSS, General Supervisors

1. Verify reason for cancellation is entered in WST, Cancel WRIF in WST.

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, Work Control Conduct Manual MWC02

, Chapter 2 Work Control Revision 8 Page $4 lCMl DLR 69 0764 in response to this DER uhtch was Issued due to improper uvra request cancellatoon 1

uhere the initiator uns not not@ed. the procedure was revised to require not@ cation ofthe originator ofcanceled w>r k requests.

2. Send copy of canceled WRIF to Initiator or originating organization.

4.10 Work Subpackages Person Step Action Re.\oonsible

[CMl ,

DER V3 0282 in response to thts DER uhich uns issued due to the discovery ofloose terminal board 93172 coversfound on EQ trarumitters, the work controlprocedure was revised to (1) require the work package planner to clearly identify each sub package and its scope on the original work request and to clearly delineate the required activities in the sub.

packages and(2) require an as built unik down with mods /maint.. the EDP owner and Ops.

t L/ [p,,nner j 4.10.1 Clearly identify each sub package and its scope on the original Work Request (for example, subpackage 1... subpackage 2..., etc.). Clearly identify the required activities in the subpackages.

[pi.nn., j 4.10.2 Obtain copies of supporting documents, checklists and forms as necessary and insert in the sub packages to provide the necessary information.

Work Group 4.10.3 Make a copy of the signed on (original) Work Request cover sheet for each supenisor subpackage, circle applicable sub package on Work Request and place copy in appropriate subpackage. ,

i v  ;

Work Control Conduct Manual MWC02 Chapter 2. Work Control O Revision 8 Page 55 4.11 Work Request Deactivation / Reactivation Person Step Action Responsible

' [o.nni servisors l 4.11.1 If Work Request must be deactivated any time after work authorization has been received complete the desetivation/ reactivation form:

NOTE: A Work Request shall not be deactivated while personnel protection is in effect.

! 1. Describe the reason for deactivation l

2. Determine the actions necessary to restore equipment to a stable or safe condition.

3. Describe the status of equipment, include any abnormal items, lG V 4. Ensure equipment status is in accordance with design documents.

5. Determine necessary P.M.T. for work that was performed to return the equipment or other affected equipment to service.

[CMl DER V3 0282 in response to this DER u hich uns assued due to the discovery ofloose terminal board 93172 coversfound on EQ transmitters, the work controlprocedure uas revised to (1) require the nork package planner to clearly identify each sub package and its scope on the original u ork request and to clearly dehneate the required activities in the sub-packages and(2) require an as built ualk doun with mods'maint., the EDP owner and Ops 93191 At the July 1, j 993 ergforcement corgference, management committed to (1) ajotnt 93)93 engineering! implementing group' operations ualkdown ofallfield complete mod {fications will be done, and (2) allplant modt fications will beformally turned over to the operations organisation. A turnover checklist will be utihted The second commitment was implemented in FIP-Call l&'AfES20, Thefirst commitment is a duplicate ofRACTSitem 93)93

6. When an EDP Work Request is begun during an outage but not completed, and it must be completed during subsequent outages, deactivate Work Request after each outage until complete. Make sure As Built configurations are walked down by the EDP owner, System Engineer, Maintenance Supervisor / Modification Field h3 Engineer, and the NSS/ delegate in accordance with MES20,

" Implementation of Modifications".

Work Control Conduct Manual MWC02 Chapter 2. Work Control O Revision 8 Page 56

7. Ifjob specific RWP is involved, notify Radiation Protection of deactivation.

l

8. Notify and cancel any involved support activities (such as scaffolding, confmed space, or special permits).

9. Release personnel protection and sign off STR in accordance with MOP 12, Tagging and Protective Barrier System.

10. Return Security Work Request to NSSS for evaluation of the impact of deactivation and line through of signatures.

I 1. Return the Work Request with the completed deactivation / reactivation form to the NSS for approval, wucleer sniR sup, 4.11.2 NSS shall perform the following:

Nuclear Asslet shlRSup

1. Verify that any required post maintenance testing is completed.

2. Review and approve the deactivation / reactivation form.

3. If appropriate restore the equipment to service per MOP-05.

4. Line through the NSS/NASS authorization signature, stamp or print DEACTIVATED on the Work Request, then initial and date.

5. Return Work Request to Supervisor, Planning for revision and rescheduling.

4.11.3 Work Request which have been deactivated should be given permission to re-commence work only once.

O 5

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Work Control Conduct Manual MWC02 6 Chapter 2 - Work Control Revision 8 Pasc57

• • '* 8'N 4.11.4

1. '

• When restraints have been cleared and Woik Request is to be reactivated, deliver Work Request to Operations Work Control or RTC so appropriate information, reslews and signatures can be obtained in i

accordance with Section 4.3, Work Authorization, on a Work Request Reactivation / Authorization Form (Fonn MWC02003).

Before reactivating an EDP Work Request, have Maintenance Supervisor / Modification Field Engineer and the EDP owner review the Work Request and EDP, and make any necessary changes, to ensure (

proper implementation. Document this review in the Work Request and have both individuals sign.

END OF TEXT O

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= i e WORK REQUEST PREPARATION CIIECKLIST Ch x_)

This form is cancelled.

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DTC: TPMMWC DSN: MWC02005 Rev. I Pl/l File: 1703.22 Date Approved:Dfsf.fdDate issued:o G /09 7 File 1230.46 IP:1 J

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WORK REQUEST FEEDBACK FORM This form is cancelled.

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O EANCELLED O

DTC;TPMMWC DSN: MWC02006 Rev.1 Pl/l File: 1703.22 Date Approved: o /ao 4 9 7 Date issued: O &/097 File 1230.53-IP; I

. . . . . . . . .. -.