ML24177A173

IP 62700 Maintenance Program Implementation (Public)

ML24177A173
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Issue date:	04/04/2000
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NRC INSPECTION MANUAL IQMB

INSPECTION PROCEDURE 62700

MAINTENANCE PROGRAM IMPLEMENTATION l

PROGRAM APPLICABILITY: 2515

CORNERSTONES: Initiating Events lMitigating Systems l Barrier Integrity. ll

62700-01 INSPECTION OBJECTIVES 01.01 To verify that maintenance activities for structures, systems, and components (SSCs) are being conducted in a manner that results in the reliable and safe operation of the plant.

01.02 To supplement the maintenance rule implementation l procedure (IP 71111.12) and maintenance risk assessment and l emergent work control procedure (IP 71111.13). ll 01.03 To perform inspections following an event caused by maintenance problems or as otherwise directed by NRC management.

01.04 To take a risk-informed performance-based or results-l based approach to the inspection of maintenance activities by using plant or equipment performance data to focus inspection activities.

01.05 To evaluate maintenance by observing ongoing maintenance activities or by reviewing and evaluating maintenance history and equipment or plant performance.

62700-02 INSPECTION REQUIREMENTS This procedure is implemented to indepe ndently assess licensee l conclusions regarding extent of condition of issues, when selected l as a part of supplemental inspections using IP 95002, " Inspection l For One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area." l 02.01 Review licensee corrective action documentation, event l reports, plant operating history, equipment operating history, and maintenance records to identify equipment m aintenance problems that may have occurred in the following categories:(Particular emphasis l

Issue Date: 04/04/00 62700 l Rule Program in the high risk significant areas.)should be placed on those SSC covered by the licensees Maintenance l

a. Equipment that has a history of recurring problems.

b. Equipment whose failure resulted in a safety system actuationor plant shutdown.

c. Equipment whose failure resulted in reduced systemcapability.

02.02 For those items identified in section 02.01 above, for which the inspector has determined that the problem may be caused by inadequate maintenance, attempt to identify the cause by performing some or all of the reviews described in steps 02.02.a l maintenance rule program, then the inspector should select severalthrough 02.02.g below. (If the problems are identified by the l licensee identified problems, such as from LERs and from operating l experience, for further detailed inspection. Also, it is noted l that any "maintenance problem" has as element of inadequate l maintenance in it.)

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a. Evaluate the adequacy of pre-job planning by reviewingavailable records or questioning responsible licensee personnel to determine if the licensee performed the following pre-job planning activities:

l data for similar equipment failures.1. Reviewed plant machinery history or industry operating

l appropriate vendor recommendations into maintenance2. Reviewed vendor technical manuals and incorporate procedures.

l complex maintenance issues.3. Obtained engineering support, when needed, to address

l complex maintenance activities.4. Prepared written procedures, where necessary, to perform

l test alignments and control for exiting those alignments.5. Reviewed post-maintenance and/or post-modification system l

l identify the causes of maintenance failures.6. Used formal root-cause analysis methods, as necessary, to

l tools and equipment, or spare parts needed to perform the7. Identified special skills or qualifications, special maintenance activity.

l the overall effect on safety of performing the planned8. Assessed the total equipment out of service to determine maintenance activity.

b. Determine if the work package (work request, maintenanceprocedure, tag-out, etc.) prepared for the maintenance activity addressed the elements listed below.

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1. The procedure conforms to the licensee's administrativerequirements for format, approval, and control.

2. The procedure specifies post-maintenance testing that isappropriate for the repairs made.

3. Inspection hold points, independent verification points,or appropriate peer reviews are identified in the procedure or in a documented plan and are appropriate for the activity.

4. Supplementary reference materials, such as drawings andtechnical manuals, are adequate, controlled, and up to date.

5. The work activities are described in a level of detailthat is commensurate with the complexity of the maintenance activity.

6. Consideration is given to cleanliness requirements andpersonnel hazards such as chemical, radiological, l temperature, pressure, and electrical hazards.

7. Provisions for fire protection, and security are lincluded. l

8. Instructions and quality control checks are included toverify that environmentally qualified equipment is properly protected against moisture intrusion when reassembled and that proper EQ material, especially elastomers, have been installed.

9. Provisions for control of equipment, including liftedleads, jumpers, bypasses, and mechanical blocks are included.

10. Provisions are included, as well as methods for notifying operationsfor obtaining formal approval from operations when affected systems are removed from service, ready to be restored to normal service, or if problems are encountered.

11. Provisions for material, parts, and tool accountabilityto ensure loose items are not inadvertently left inside equipment after the work is complete.

12. Provisions for procedure or standard task prerequisites, lsuch as scaffold engineering evaluations and requests, l breach of fire/air/radiation ba rriers, and radiation l protection requirements, are included. Breach of l barriers may be a Technical Specification requirement. l

13. Replacement parts for a given job will be properly lcontrolled and identified for its end-use (ANSI N18.7 of l the licensees Topical Report, Technical Requirements l Manual/Chapter 17 of Final Safety Analysis Report l (TR/FSAR)). l

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c. Review the completed work package (work request, maintenanceprocedure, tag-out, etc.) for the selected work activity to determine whether:

l beginning the work.1. Required administrative approvals were obtained before l

2. Technical Specification limiting conditions for operationwere met while the component or system was removed from service.

3. Approved exceed the normal skills possessed by qualifiedprocedures were used if the activity appeared to maintenance personnel.

4. Quality control (QC) inspections were made in accordancewith the licensee's requirements, and QC r ecords were completed.

5. Functional testing and calibrations were completed andtest data was reviewed by supervision and verified to l criteria before returning the equipment to service.meet all Tech nical Specifications and licensee acceptance

6. Personnel who performed the tests were properly qualifiedand trained for special tests.

7. Activities performed by outside contractors werecontrolled in accordance with the licensee's approved quality assurance program or a licensee-approved QA program commensurate with the activity.

8. System failures that necessitated the maintenance wereevaluated and reported in accordance with 10 CFR 50.73, if required.

9. Corrective and preventive maintenance records wereupdated, assembled, and stored as part of the maintenance history. Information added to industry-wide databases as appropriate (e.g. NPRDS).

l within calibration date limits, and appropriate for its10. Measuring and test equipment (M&TE) used was identified l end-use.

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11. Parts and materials used were identified and at least metthe specifications of the original equipment. Appendix B requirements were met or commercial grade dedication was completed where required.

12. Special processes were controlled and documented.

13. System lineups were made and verified before returningthe system to service. Retests were completed and any out-of-specification test results were appropriately addressed.

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d. Determine if M&TE was appropriate for critical measurementsaffecting equipment operability. Review those M&TE records to verify:

1. The M&TE was in calibration at the time of use.

2. The calibration of the M&TE can be traced to nationallyrecognized standards.

3. The M&TE is properly stored, controlled, identified witha unique number, and labeled with calibration status.

4. M&TE is calibrated against standards that have anaccuracy that is better than or equal to the instrument being calibrated.

e. Review the calibration records for safety-rel ated plantinstruments, preferably those associated with the selected maintenance activity. Include at least one instrument that was not specifically required to be calibrated by technical specifications (TS), but was relied upon during the performance of a TS surveillance test. Verify the following:

1. The instrument calibration history is kept up to date.

2. The calibration of these instruments is traceable tonationally recognized standards and the cali bration accuracy ratio is in accordance with generally accepted industry standards.

3. The person who calibrated these instruments is clearlyidentified and qualified to perform the calibration. l

4. An approved procedure was used to perform the lcalibration.

f. Review the preventive maintenance program and verify thefollowing:

1. Preventative maintenance (PM) activities are performed asscheduled. When not performed as scheduled, management controls are followed to defer and/or reschedule the PM.

2. Equipment failures should be evaluated to determine ifthe preventive maintenance program could be changed to prevent future failures.

3. Preventive maintenance procedures are available and aresufficiently detailed.

4. A lubrication control system is available and kept up todate.

5. Preconditioning and does not ensure success of testing. lequipment prior to testing is controlled l l

Issue Date: 04/04/00 62700 l prioritization, timing of repairs, and managing ofg. Check whether the licensee has appropriately considered the l maintenance work items backlog.

l 02.03 Select a number of corrective and preventive maintenance activities that are in progress, preferably those that are related to problem components or systems. For the maintenance activities selected, verify the following:

a. Maintenance personnel assigned understand the scope of thetask.

b. Applicable parts of items 02.02.b and 02.02.c are satisfiedfor the work in progress.

c. The maintenance personnel are qualified for their respectivetasks.

d. Supervisory oversight of the work is adequate.

e. QC personnel assigned are knowledgeable of the task.

l recurrence.f. Apparent cause of failure appears to be addressed byappropriate corrective action, including measures to prevent l

l g. Personnel are following up-to-date procedures.

l h. Appropriate health physics support available.

62700-03 INSPECTION GUIDANCE General Guidance l maintenance rule, 10 CFR 50.65 (see IP 62706, IP71111.12 and IPUse this procedure in conjunction with the requirements of the l 71111.13 when inspecting those activities associated with SSCs l identified as having poor performance by the licensees monitoring l program. See IP 62706 for additional details on cause l determination analyses, corrective actions, goal setting and l monitoring needed to improve SSC performance. The results of risk-l informed, performance-based inspections may reveal maintenance l program implementation concerns.

l l Evaluate the significance of the event, p erformance of safety l systems, and actions taken by the licensee. Determine whether l goals established for the performance of SSCs are commensurate with l safety, and where practical, industry-wide experience was applied.

l l safety-significant aspects of the maintenance process, includingData collection should be directed to those measures related to l determining whether goals established for the performance of SSCs l

62700 Issue Date: 04/04/00 are commensurate with safety, and whether practical industry -wide l experience was applied. ll As appropriate, review provisions established to track l unavailability time, and evaluate maintenance activities for l identification of maintenance preventable functional failures as l defined in Regulatory Guide 1.160 revision 2 and NUMARC 93-01, l Revision 2. ll The inspector should be aware that additional guidance is available l for evaluating any human performance problems observed during the l inspection. IP 71841 and Human Performance Investigation Process l (NUREG-CR 5455) provide additional guidance. l Inspection requirements listed in Section 62700-02 describe the maintenance elements to be considered by the inspector in completing this aspect of the inspection program and in arriving at conclusions with regard to the objectives of the inspection procedure. Depending on the inspection entry point, i.e., the l reason the management has invoked the use of this IP, IP sections l may be used to concentrate on featured results-based activities. l Additional specific guidance is described below. l As with all inspection procedures, the inspector is not required l to complete all the inspection requirements listed in 02.01, nor be limited to those inspection requirements. The inspector may choose to explore any aspect of maintenance that appears to warrant further review.

Specific Guidance The specific guidance listed below provides additional information intended to clarify the inspection requirements listed in paragraphs 02.01, 02.02, and 02.03. The designations used below correspond to the letters used in paragraph 62700-02 (i.e.,

paragraph 03.01 provides specific inspection guidance for inspection requirement 02.01). The inspection sh all em phasize l reviewing those activities associated w ith SSCs identified as l having poor performance by the licensees monitoring program l established to comply with the requirem ents of the maintenance l rule, 10 CFR 50.65 (see IP 62706, IP71111.12 and IP 71111.13). l 03.01 The number of equipment maintenance problems selected for review by the inspector will depend on the num ber of inspection hours allotted for the task by regional management and the scope and complexity of the maintenance tasks selected for review. The inspector will focus the inspection on what appears to be the most l severe problem area and continue until the problem has been l resolved. The inspector will then focus on the next problem area until that is resolved satisfactorily. There is no minimum number of problems that must be inspected during each inspection. If the inspector identifies a problem that cannot be resolved during the planned inspection period, the inspector will advise regional management that additional inspection hours should be allotted to resolve the issue.

Issue Date: 04/04/00 62700 03.02 If the plant equipment performs reliably and remains capable of performing its intended functions, there may be no need for the inspector to further examine the licensee's program or procedures by performing steps 02.02.a through 02.02.f. The inspector should perform only those steps that are appropriate considering plant and equipment reliability.

a. Licensees are not required to perform all of the activitieslisted in section 02.02.a (1-6) as part of the pre-job planning for all maintenance activities. However, the inspector should expect that the licensees had performed those pre-job planning activities that were appropriate considering the complexity and scope of the maintenance activity.

a.1 No inspection guidance.

a.2 While it is required for licensees to obtain and reviewvendor technical information, it is not required that all vendor recommendations be incorporated into the licensee's maintenance program. If the licensee determines that a vendor r ecommendation is not appropriate, the licensee may decide to disregard it. However, if equipment problems result in unacceptable loss of essential function, determine if vendor recommendations that could have precluded the l Assessment Team Inspection report 50-311/97-80 providesproblems were adequately implemented. Salem Readiness l examples of potential vendor manual focal points. [Sections l 3.3.5 and 3.4.5: are available on the external NRC web site]

l Verify that the licensee has established an adequate vendor interface program. Additional information on this subject is provided in Generic Letter 90-03, "Relaxation of Staff Position in Generic Letter 83-28, Item 2.2 Part 2, Vendor Interface For Safety-Related Components,' dated March 14, 1990."

l a.3-8 No inspection guidance.

b. Licensees are not required to address all of the elementslisted in section 02.02.b (1-11). The work package should be tailored to the complexity and scope of the maintenance activity. The inspector should expect that the appropriate elements were addressed by the licensee.

To assess the general control of maintenance activities, the scope of work packages reviewed can be expanded outside the items identified in 02.01. It is not ne cessary to review each work package selected against each of the criteria specified. It is left to the discretion of the inspector to ensure that a sufficient number of work packages are checked to develop some confidence that the individual attributes specified are being adequately addressed by the licensee.

Because of the administrative complexity of maintenance work packages, avoid emphasizing nonrecurring minor administrative deficiencies, such as missing dates and in complete forms.

These minor issues must be brought to the attention of the

62700 Issue Date: 04/04/00 licensee but should not distract the inspector from evaluating the overall effectiveness of the licensee's maintenance activities.

b.1 Regulatory Guide 1.33 provides exception for the generationof maintenance procedures for activities such as gasket replacement, troubleshooting of electrical c ircuits, etc.

This is based on the assumption that these activities are part of the basic skills possessed by qualified maintenance personnel. The licensee should have guidance as to the level l of detail required for steps in a maintenance procedure. l Site maintenance training and administrative procedures l should define what is "skill of the craft." This writers l guidance should have several sources of input such as INPO l and/or EPRI. ANSI N18.7, Section 5.0, and the licensees l Technical Specifications have general procedure content l requirements. Basic skill failures should be investigated as l maintenance training program issues. l b.2 As specified by the licensees procedures, appropriate post lmaintenance or modification tes ting will be performed. l Examples of required testing are: replacement component and l weld testing should be in accordance with the code of record; l modifications may require revised code of record testing; l preservice and/or Inservice (ISI and IST) tests may be l required under ASME Code Section XI with possible code l exemptions; augmented ISI testing may be required due to l commitments; and functional tests should be detained in the l work packages. In some instances, the standard component or l system surveillance tests may not be sufficient to establish l functionality (e.g., on a pump impeller or casing l replacement). Special test prerequisites and system l alignments should be detailed in the package. l b.3-5 No inspection guidance. l b.6 Work controls should have specified or general site lprocedures should account for foreign material exclusion, l chemical controls, and hazard checks. The general site l instructions are often required to be in the work packages as l standing, standard written instructions (to reduce a memory l burden). Foreign material controls should be clear in their l intent to prevent material entry. Inspections such as l quality control hold points for cleanliness should occur l prior to closure of boundaries (e.g., valve or pump l reassembly). Chemicals should be clearly marked and l controlled from use in specific applications (e.g., halide l primary internals or stainless stee ls). Zero power checks lcontaining water or cutting fluids should not be used on l should be standard training or a standing instruction prior l to performance of electrical work. ll b.7 No inspection guidance. l b.8 The June 1984 AEOD report, AEOD/C402, "Operating ExperiencesRelated to Moisture Intrusion in Electrical Equipment at Commercial Power Reactors," studied failures of environmen-

Issue Date: 04/04/00 62700 tally qualified electrical devices in mild environments. In most cases these failures resulted from moisture intrusion that was often caused by improper reassembly of enclosures following maintenance or surveillance activities. Therefore, maintenance programs should include adequate controls to ensure the restoration of vapor barriers, gaskets, and seals to an environmentally qualified condition.

l b.9-13 No inspection guidance.

l c.1-4 No inspection guidance.

l Technical Requirements Manual/FSAR), testing and its statusc.5 As required by ANSI N45.2 and N18.7 (from the licensees l shall be controlled. Test equipment and instruments specific l for the testing should be clearly identified. Test l acceptance criteria shall be in the package along with sign l off locations and appropriate review requirements. Test l deficiencies shall be properly evaluated generally through l the corrective action program. Equipme nt status should be l known and documented prior to return to service.

l l c.6 No inspection guidance.

l activities that are under 10CFR50, Appendix B, and thec.7 Depending on the entry point to this IP, contractor l licensees Quality l inspection. See licensees TR/FSAR for the originalAssurance Program may require detailed l standards l problems are described in various Information Notices, suchrequirements. Examples of contractor control l as IN 94-13 (though supplement 2) and IN 80-26.

l l c.8-10 No inspection guidance.

l c.11 Replacement parts, whether purchased, manufactured, orfabricated, should at least meet the specifications and requirements of the original equipment. In some cases, however, reanalysis of accident conditions may result in more severe environmental conditions than those to which the original equipment was procured. This would require the upgrade of replacement parts to withstand the more severe environmental conditions. Therefore, ensure that the documented basis for the environmental qualification of replacement parts correctly reflects the environmental conditions resulting from the revised accident analysis.

c.12-13 No inspection guidance.

d.1-3 No inspection guidance.

d.4 Calibration of M&TE should be against standards that have anaccuracy of at least four times the required accuracy of the equipment being calibrated or, when this is not possible, have an accuracy that assures the equipment being calibrated will be within required tolerance and that the basis of acceptance is documented and approved.

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e. Assistance in selecting the instrument records to be reviewedcan be gotten from the licensee's quality list, from the instrument index, or through personnel i nterviews. The instruments selected should be considered to be safety-related based on their function rather than the fact that they provide a safety-related pressure boundary, such as for an ASME Code class piping system.

f-g. No inspection guidance.

03.03 The inspector will consider safety significance when selecting maintenance activities for observation. Choose components that have had problems or activities, such as inadequate training or procedures, that have resulted in maintenance problems.

Evaluate the rate of failures, not just the number of failures.

The plant-specific proba bilistic risk assessment (PRA) or individual plant examination (IPE) can provide information on the risk significance of plant equipment. l a-c. No inspection guidance.

d. Adequate supervision by experienced personnel of maintenancework in progress is considered to be an essential element of an effective maintenance prog ram. Through interviews with supervisory and nonsupervisory maintenance personnel, determine whether maintenance supervisors, such as foremen, have enough time available to supervise work in progress and whether the intended amount of supervision is actually taking place.

e-h. No inspection guidance. l

62700-04 RESOURCE ESTIMATE The resource estimate for this inspection procedure is approximately 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> of direct inspection effort.

62700-05 REFERENCES U.S. Code of Federal Regulations, "Requirements for monitoring the l effectiveness of maintenance at nuclear power plant s," 10 CFR l 50.65. ll U.S. NRC, "Monitoring the Effectiveness at Nuclear Power Plants," l Regulatory Guide 1.160. ll Nuclear Management and Resources Council, "Industry Guideline for l Monitoring the Effectiveness of Maintenance at Nuclear Power l Plants," NUMARC 93-01. ll ANSI 18.7/ANS 3.2, "Administrative Controls and Quality Assurance l for the Operational Phase of Nuclear Power Plants" l

END

Issue Date: 04/04/00 62700