W3P86-0019, Responds to NRC Re Violations Noted in Insp Repts 50-382/85-04 & 50-382/85-27.Corrective Actions:Nuclear Purchasing Procedure Revised to Include Issuance of Ack Copy of Purchase Order Changes for safety-related Orders
| ML20215F569 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/14/1986 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20215F556 | List:
|
| References | |
| W3P86-0019, W3P86-19, NUDOCS 8610160268 | |
| Download: ML20215F569 (17) | |
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E POWER & LIGHT IOUISIANA 442 Deu nONOe S1neer P O. BOX 6008
- NEW OnLEANS. LOUISIANA 70174 * [504) 366-2345
$UNdYS February 14, 1986 W3P86-0019 A4.05 QA
"' [H(P [!,(l'
'F" qh Mr. Robert D. Martin
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Regional Administrator, Region IV ll '
j U.S. Nuclear Regulatory Commission i(
(($ l 8 l% ;
611 Ryan Plaza Drive, Suite 1000
- i Arlington, TX 76011 J
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Reports 85-04 and 85-27
Dear Mr. Martin:
Attachment A has the Louisiana Power & Light Company (LP&L) responses to Violations numbered 8504-01, 8504-03, 8527-03 and 8527-05 which were cited in the subject NRC Inspection Reports. Additionally, per the verbal request from NRC Region IV, LP&L is providing an " Overview of Waterford 3 Maintenance Program" (see Attachment B).
If you have any questions on the responses, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.
Very truly yours, 8610160268 861006 PDR ADOCK 0000 2
/t gy K.W. Cook Nuclear Support & Licensing Manager KWC:GEW:ssf Attachments cc:
NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR l
NRC Resident Inspectors Office l
B.W. Churchill W.M. Stevenson ze as/a.
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- t, ATTACHMENT A W3P86-0019 Sheet 1 of 10 LP&L Response To Violations in Inspection Reports No. 85-04 and 85-27 1.
VIOLATION 8504-01 Inadequate Documentation for EBASCO Safety-Related Ventilation Heating System and Replacement Parts Used With Charcoal Filters 10 CFR 50, Appendix B, Criterion VII, requires that documentary evidence that material and equipment conform to design procurement requirements on which the plant was licensed shall be available at the nuclear power plant.
Contrary to the above, licensee documentation from the vendor stated that the purchase order requirements were considerably beyond those under which the original equipment was manufactured, though original equipment procurement documents contained these requirements.
The licensee deleted the design procurement requirements and accepted the replacement parts.
This is a Severity Level IV.
RESPONSE TO VIOLATION (1) Reason for Violation No violation occurred. The purchase order in question (P.O. L260980) included both safety-related and commercial grade spare parts. This distinction was determined upon notification from the supplier that exceptions to the procurement requirements were being taken. An engineering evaluation was completed at that time resulting in safety-related spare parts (heating elements) being deleted from the purchase order.
The remaining commercial grade spare parts were procured on the above P.O.
The safety-related items were subsequently purchased on P.O. No. L34650D, dated July, 1983 with special quality requirements imposed including imposition of LP&L witness and inspection hold points at the vendor's facilities.
(2) Corrective Action That Has Been Taken Plant Operating Procedures in effect since November, 1984 require a documented engineering evaluation prior to procurement or installation of any item for a safety-related system, structure or component that has been determined to be commercial grade, or was procured non-safety related.
(3) Corrective Action That Will Be Taken No further action is intended.
(4) Date When Full Compliance Will Be Achieved Full compliance was achieved on November 15, 1984.
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-ATTACHMENT A 8 *
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W3P86-0019 Sheet 2 of 10 C
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VIOLATION NO.' 8504-03
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Licensee Procedures for Maintenance of Equipment Qualification and
' Procurement of Spare Parts 10 CFR 50, Appendix B, Criterion V, requires, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Contrary to the above, the licensee did not have procedures which:
1.
Verified supplier acceptance of, and verification of compliance (where required), or changes to safety-related purchase orders
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which affect design or quality.
2.
Required design change review, including 10 CFR 50.59 review, for Purchase Order major exceptions which delete technical or quality requirements contained in Architect Engineer (AE) or other design specifications used to assure the design base upon which the plant 4
was licensed.
i 3.
Assured the review of previously procured spare and replacement i
material, parts and components, and future procurement of such parts are reviewed against the final, "as-built" Ebasco design and procurement specifications for design and quality changes which affect reactor plant safety, i
l 4.
Implemented maintenance of equipment qualification prior to fuel l
load as committed in Section A6. of Revision 2 (November, 1982) of LP&L's Waterford SES Unit No. 3 Response to NUREG-0588.
This is a Severity Level IV violation.
f RESPONSE TO VIOLATION (1) Reason for The Violation For Part 1.
At the time of the inspection, supplier acknowledgement and acceptance l
of purchase order revisions was not a procedural requirement.
However, proceduralized distribution of revisions to purchase orders was in effect which included a copy to the warehouse to be used by f
receipt inspection. The acceptance of material received to incorrect requirements resulting from P.O. revision would, therefore, have been r
prevented by the receiving inspector.
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- ATTACHMENT A W3P86-0019 Sheet 3 of 10 For Part 2.
LP&L did have procedures in place in November, 1984 to assure that technical and quality exceptions or changes to purchase orders received an engineering evaluation. UNT-8-001, Revision 8, approved 11/15/84, states that major exceptions and changes are forwarded to Plant Engineering via completion of a Spare Parts Equivalency Evaluation form (SPEER). The SPEER form includes a 10CFR50.59 screening process to determine the need for a safety review.
For Part 3.
Updating and transmittal of Ebasco "as-built" design disclosure documents are in need of improvement. However, LP&L had procedures in place which reduced the possibility of error in applying inaccurate requirements to procurement documents.
UNT-8-001, " Processing of Procurement Documents", has always required that the latest design disclosure documents be researched to determine and replicate previous requirements.
Further, PE-2-006, " Plant Engineering Station Modifications", includes requirements to check existing open spare parts orders as well as purging the warehouse stock, where appropriate.
For Part 4.
At the time of fuel load, LP&L had procedure PE-2-014, " Equipment Qualification", in place which addressed LP&L's equipment qualification program. Efforts have continued to optimize the effectiveness of the program. Maintenance requirements were incorporated into the program as they became known.
(2) Corrective Action That Has Been Taken For Part 1.
LP&L has revised its nuclear purchasing procedure, PMP-103,
" Preparation and Processing of Purchasing Documents", to include issuance of an acknowledgement copy of P.O. changes to the vendor for safety-related orders. Vendors are currently required by wording on the standard LP&L P.O. form to provide an acknowledgement. An acknowledgement copy is now being provided to ensure consistency of the format of vendor response.
Further, a log is now maintained of acknowledgement copies sent go vendors.
Failure of a vendor to send proper acknowledgement within a reasonable period of time results in special expediting of the acknowledgement.
Plant Procurement Procedure UNT-8-001 was revised to include the requirement in the purchase order for the vendor to indicate the LP&L purchase order number and any revisions thereto on the certificate of conformance/ compliance accompanying the item / material.
For Part 2.
No additional action is deemed necessary.
1 ATTACHMENT A W3P86-0019 Sheet 4 of 10
~For Part 3.
LP&L is in the process of reviewing the Ebasco design and procurement specifications to determine the scope and significance of revisions to those_ specifications, to determine in the aggregate, if any significant differences exist between the specifications and the current configuration of the plant. The scope of the task includes review of all technical changes to the specification and comparison of those changes with the as-built configuration of the plant.
133 specifications are currently scoped into the task.
At present, approximately 80 specifications have been reviewed for seismic and environmental revisions. The estimated completion date for the entire task is 6/15/86.
At this time, no discrepancies have been identified which would have had adverse impact on the installations, replacement material, parts or components built or procured to the specification.
In addition, in December, 1985, the Plant Procurement Section was issuedacontrolledsetofdesignspeci{tcationsandcontrolledEQ list to ensure that spare / replacement parts are procured to the latest requirements. Additionally, a project evaluation /information request is generated for those items to be procured for a safety-reinted system, structure or component when the technical / quality requirements for the item / material are not explicitly defined in the design specification.
For Part 4.
LP&L instituted an equipment maintenance program based on verdor technical marual it. formation and industry practice. The evolution of this program, including technical manual and procedure review and updating has been addressed in the response to NRC Inspection Report 84-25, Violation 8425-01.
The plant is being maintained under this program with the addition of maintenance requirements for EQ components which may not have been included in the vendor technical manuals.
Since the February, 1985 NRC inspection, LP&L has implemented a much improved EQ program which is responsive to 10CFR50.49. This program and its procedures adequately address EQ maintenance. EQ program and procedure training has been completed for applicable Waterford 3 personnel.
During November and December of 1985, LP&L reviewed maintenance activities to determine if the qualification of equipment had been impacted by either the lack of or insufficient maintenance.
In some cases 0-rings were replaced in order to comply with manufacturer requirements which were found not to have been incorporated in the work instructions.
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.s' ATTACHMENT A W3P86-0019 Sheet 5 of 10 (3) Corrective Action That Will Be Taken For.Part 1.
No additiong1 corrective action needed.
For Part 2.
No additional action deemed necessary.
For Part 3.
The results of engineering specification review due in June, 1986 will determine whether additional action is necessary.
For Part 4.
No additional action deemed necessary.
(4) Date When Full Compliance Will Be Achieved For Part 1.
Corrective Action was completed November, 1985.
For Part 2.
No corrective action was required.
For Part 3.
The estimated completion of the engineering review is June, 1986.
For Part 4.
Corrective action has been implemented with the issuing of EQ Maintenance instructions commencing in October, 1985.
It is recognized that there are some evolutionary requirements in the industry's approach to EQ and LP&L intends to satisfy these requirements in an expeditous manner when they become known.
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- ATTACHMENT A
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W3P86-0019 Sheet 6 of 10 3.
VIOLATION NO. 8527-03 Failure to Establish Adequate Procedures Technical Specification, Section 6.8.1 (Regulatory Guide 1.33, Section 9; and ANSI N18.7-1976, Section 5.2.7) and Criterion V of Appendix B to 10 CFR 50, as implemented by licensee Quality Assurance Program, FSAR Section 17.2.5, require that written procedures shall be established for control of quality-related functions, including maintenance activities.
Contrary to the above:
1.
Licensee Procedure PE-2-014 " Equipment Environmental Qualification," Revision 2, included requirements to assure identification and control of maintenance of equipment qualification, but failed to provide adequate control of classification of these maintenance activities in that preventive maintenance (PM) tasks involving equipment qualification (EQ) maintenance activities were not adequately identified and controlled.
2.
Licensee Procedures MI-5-503, Revision 0, Change 2; MI-5-201, Revision 3, Change 1; and MI-3-315, Revision 2, Change 1, which were issued to perform preventive maintenance to maintain component qualification, did not include 0-ring replacement and lubrication or torquing of instrument covers required to maintain component qualifications for safety-related preventive maintenance documented on task cards CCS IP 515 X A 25 [ sic), SI IL 0321 01 [ sic), and CP IP 6702 MC 1 [ sic].
This is a Severity Level IV violation.
RESPONSE TO VIOLATION (1) Reason For The Violation For Part 1.
PE-2-014 did not provide sufficient procedural guidance to adequately deal with the particular item noted.
The calibration check of a Rosemount 1153 transmitter does not affect the environmental qualifict. tion of the transmitter because no adjuctments are made and the covers are not removed. A calibration, however, requires the covers to be removed, and is an EQ task. Tasks initially issued as calibration checks which subsequently became calibrations were not properly reclassified as EQ tasks.
For Part 2.
Preventive maintenance tasks were performed in accordance with existing procedures.
. p :s ATTACHMENT A-W3P86-0019 Sheet 7 of 10 The tasks identified in the violation were performed prior to incorporation of the! maintenance items recommended by the vendor in the Equipment Qualification package into plant maintenance procedures.
Previous maintenance procedures had omitted this maintenance task which was in the vendor technical manual.
The date on which each task was accomplished and the procedure related to each task is as follows:
1)
CCS-IP-5158A Task 25 3/16/85 MI-5-503 Revision 0, Change 1-2)
SI-IL-0321' Task 01 1/15/85 MI-5-201 Revision 3 3)'
CP-IP-6702 Task 01 6/10/85 MI-3-315 Revision 2 The versions of the procedures used for these tasks did not include "O" ring replacement and lubrication or torquing of instrument covers.
During the review of the Equipment Qualification packages, changes were incorporated into plant procedures to implement the requirements of the package as they were identified. Such changes were made to the following procedures on the dates indicated to incorporate the requirements to replace the 0-rings utilizing Dow Corning 55M lubricant and to torque the cover to 200 in/lb. whenever the electronics enclosure cover of a model 1153 Rosemount transmitter is removed.
1)
MI-5-503, Revision 0, Change 2 September 6, 1985 2)
MI-5-201, Revision 3 Change 1 June 7, 1985 3)
MI-3-315, Revision 2, Change 1 July 1, 1985 (2) Corrective Action That Has Been Taken For Part 1.
Additional station procedures have been written to provide the necessary controls and guidance. The following EQ procedures are in placet NOP-009 Equipment Qualification UNT-1-015 Equipment Qualification Program MD-1-020 Equipment Qualification Program PE-2-014 Equipment Qualification Support PMP-325 Equipment Qualification PMI-309 Preparation of Environmental Qualification Assessment Reports PMI-310 Development Control and Issue of EQ List PMI-311 Development and Update of the EQ Data Base PMI-312 Use of Materials Aging Data Base PMI-313 Development of EQ Maintenance Inputs These procedures require that an EQ Data Record Form from MD-1-020 be completed when any maintenance is performed on EQ equipment. The EQ Data Record Forms identify the EQ requirements for each piece of
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ATTACHMENT A t
W3P86-0019 Sheet 8 of 10 equipment. -In the case of the Rosemount 1153 transmitters, maintenance performed now is considered EQ maintenance except calibration checks.
Procedure MD-1-020 provides the required guidance to reclassify calibration checks which subsequently become EQ Maintenance.
For Part 2.
In conjunction with the EQ program, 0-rings were replaced using a proper lubricant and the access covers were torqued during the last quarter of 1985 on the Model 1153 Rosemount transmitters located in the containment.
(3)
Corrective Action To Be Taken For Parts 1 & 2.
No further action is deemed necessary.
(4) Date When Full Compliance Was Achieved i
For Part 1.
l December 31, 1985 For Part 2.
December 31, 1985 l
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ATTACHMENT A W3P86-0019 Sheet 9 of 10 4.
VIOLATION NO. 8527-05 Failure to Implement Procedures Technical Specification, Section 6.8.1 (Regulatory Guide 1.33, Section 9; and ANSI N18.7-1976 Section 5.2.7) and Criterion V of Appendix B to 10 CFR 50, as implemented by licensee Quality Assurance Program, FSAR Section 17.2.5 require that written procedures shall be implemented for control of quality-related functions, including maintenance activities.
Contrary to the above:
1.
Licensee Procedure MI-3-323, Revision 2, Change 2, required replacement and lubrication of instrument cover 0-Rings, but these requirements were not accomplished for PM task card RC ILO 00lX 01.
2.
Licensee Procedures UNT-8-042, Revision 1, and UNT-7-021, Revision 0, required performance of a Spare Parts Equivalency Evaluation Request (SPEER) prior to use of a part, but for Condition Identification Work Authorization (CIWA) 15517, 0-Ring part number 011 51-002 did not have required SPEER prior to use.
i This is a Severity Level IV violation.
RESPONSE TO VIOLATION (1) Reason For The Violation For Part 1.
The preventive maintenance task was performed in accordance with procedures existing on June 19, 1985.
The worker utilized MI-3-323, Revision 2, Change 1 in the accomplishment of preventive maintenance task RC-ILT-0110X, Task 01 on June 19, 1985.
This version of the procedure did not include the requirement to replace and lubricate the instrument cover "0" rings.
The inspector referenced MI-3-323, Revision 2, Change 2 which was approved on July 1, 1985 to incorporate maintenance items identified in the review of the Equipment Qualification package, i
For Part 2.
l The violation occurred because plant staff did not follow procedure UNT-7-021.
(2) Corrective Action That Han Been Taken For Part 1.
Records of the task performance indicate that an 0-ring set was requisitioned from the warehouse on June 19, 1985, for use on RC-ILT-0110X. The records, however, do not document the application
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.D ATTACHMENT A W3P86-0019 Sheet 10 of 10 For Part 1.
of any lubricant to the access cover 0-rings.
The 0-rings on the access covers of transmitter RC-IL-0110X were replaced using a proper lubricant and the access covers were torqued to 200 in/lbs. during the last quarter of 1985 in accordance with the EQ program.
For Part 2.
The 0-rings were replaced during a subsequent calibration of RC-IDPT-0111 on 3/26/85 on CIWA 015836.
4 Controls on the issuance of material frota the warehouse have been improved by retraining of warehouse personnel on the requirements of UNT-8-044, " Requisition and Return of Items To Stores." Items are issued from the warehouse to the "as purchased" specifications and no deviations to Requisition on Stores forms are allowed, unless properly evaluated and authorized.
(3) Corrective Action That Will Be Taken I
For Parts 1 & 2.
No further corrective action is deemed necessary.
(4) Date When Full Compliance Will Be Achieved For Part 1.
l December 31, 1985 1
For Part 2.
i The "0" rings were replaced on 3/26/85.
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ATTACHMENT B W3P86-0019 Sheet 1 of 5 OVERVIEW OF WATERFORD 3 MAINTENANCE PROGRAM An evaluation of virtually all aspects of the maintenance program at Waterford 3 has been undertaken. Changes in procedures, emphasis and direction have been instituted. Many of the initiatives to strengthen the overall maintenance program have been completed; some are long term projects or continuing programs.
Among these efforts are:
1.
Maintenance work flow:
The existing flow of maintenance work was reviewed, evaluated and modified to increase productivity and ensure the reliable performance of maintenance activities and documentation.
The approved revision of the station's maintenance work flow was a major input to an extensive revision to Condition Identification and Work Authorization (CIWA) procedure, UNT-5-002.
The highest levels of Plant Management were intimately involved in the revision to the procedure.
2.
Condition Identification and Work Authorization Procedure:_ The CIWA procedure is the primary controlling document for corrective maintenance activities at Waterford 3.
This procedure prosides the method to initiate the documentation of abnormal conditions; the process to evaluate abnormal conditions and prepare corrective action packages; the means to authorize corrective action; and the forms and appropriate directions to document evaluations, concurrences, approvals, work performance and reviews. This procedure was reviewed by virtually all levels of supervision of the affected organizations and was extensively revised and subsequently approved on January 13, 1986. The revision incorporated the approved Maintenance work flow and in particular, those recommendations by maintenance first line supervisors, department heads and managers responsible for work in the field.
Specifically, the rcvised procedure is designed to:
o be easier for the technicians to properly use; o
be more efficient and more logical; o
eliminate unnecessary duplication of information; o
partially implement the Station Information Management System (SIMS); and o
improve data capture for Maintenance history.
3.
Vendor information:
Safety related vendor technical manuals have been reviewed to ensure that vendor recommended preventive maintenance activities have been incorporated into our Preventive Maintenance Program and that any deviations from recommendations have been evaluated. Additionally, vendor manuals were reviewed to ensure that recommend 3d retest requirements were compatible with applicable station procedures.
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or ATTACHMENT B W3P86-0019 Sheet 2 of 5 4.
Vendor / Equipment Technical Information Program (VETIP): Louisiana Power and Light has committed to implement the VETIP program developed by the NUTAC in Generic Letter 83-28.
The VETIP was implemented by LP&L in January 1985. Procedures have been developed by all reviewing / screening groups to ensure that all incoming vendor information receives an appropriate review.
Each piece of vendor information is tracked throughout the review process and each step of the review process requires an appropriate signature.
Action items such as procedure changes arising in the review process are tracked through completion. For items not requiring review, this review process can be bypassed with appropriate supervisory approval.
It is the responsibility of the receiving organization to ensure that vendor information is entered into the VETIP. This responsibility has been incorporated into the General Employee Training program.
5.
Maintenance Organization: An additional three Maintenance Engineers L
have been authorized raising the total to six Maintenance Engineers.
Efforts to fill the additional positions are in progress.
6.
Non-maintenance group participation to assist maintenance effort:
Several groups, outside the Maintenance Department, have provided support and expertise in order to enhance the maintenance effort.
The Training Department's lead maintenance trainer assisted in the work flow study and the CIWA procedure revision. He observed the CIWA work flow in the field, interviewed personnel at the working level and revieved in-process paperwork.
From this review he was able to make a number of recommendations which were subsequently incorporated into the CIWA procedure revision.
Several QA Department personnel performed a review of corrective maintenance (CIWA's) and PM Task Cards for work performed on EQ equipment since fuel load. QA personnel accessed what specific work and modifications were made to EQ equipment by plant CIWA program utilizing the Tandem computer system in accordance with PMP-306. As CIWAs were identified to specific UNID numbers, they were evaluated with regard to the problem or failure description and a determination from a quality standpoint was made whether any potential EQ problem existed with the activity performed. This information was given to Engineering for investigation and evaluation. This review determined the environmental qualification of the equipment was maintained. A formal OA Audit of the Environmental Qualification Program is currently underway and scheduled to be completed prior to the end of February.
Whenever the opportunity arises, non-maintenance organizations will continue to be employed to provide technical assistance to maintenance activities.
7.
QC trained maintenance technicians: Twelve maintenance technicians have been trained and five are fully certified to perform QC inspections of routine maintenance activities in their respective disciplines per procedure QI-10-001, " Inspection".
It is expected
ATTACHMENT B W3P86-0019 Sheet 3 of 5 that certification of the remaining seven personnel will be obtained in the near future. Training of additional personnel is continuing in order to meet a goal that 25 percent of the inspections are performed by maintenance personnel.
It is expected that this training and " hands on" participation in a portion of our Quality Control Program will enhance the awareness and sense of responsibility in Waterford 3 technicians.
It is also expected that this participation will result in further suggestions and ideas for improvement from those who are in a good position to view the effectiveness of our program and who are immediately responsible for Ouality - the workers. The Plant Manager - Nuclear has personally discussed our desire for this program in a meeting with all maintenance supervision.
8.
Equipment Qualification (EQ) Program Implementation: The Waterford 3 Equipment Qualification Program was implemented to meet the November 30, 1985, commitment date. The Program includes:
o A formal organization with authority that crosses normal organizational boundaries to ensure the ability to rapidly and efficiently implement EQ actions was formed.
o Procedures. Waterford 3 has established nine new procedures and rewritten one existing procedure. They are:
(1) NOP-009 Equipment Qualification, (New)
(2) UNT-1-015 Equipment Qualification Program (New)
(3) MD-1-020 Equipment Qualification Program (New)
(4) PE-2-014 Equipment Qualification Support (Rewrite)
(5) PHP-325 Equipment Qualification (New)
(6) PMI-309 Preparation of Environmental Qualification Assessment Reports (New)
(7) PMI-310 Development Control and Issue of EQ List (New)
(8) PMI-311 Development and Update of the EQ Data Base (New)
(9) PMI-312 Use of Materials Aging Data Base (New)
(10) PMI-313 Development of EQ Maintenance Inputs (New)
These procedures establish EQ responsibilities from the Senior Vice President-Nuclear Operations through Project Management Engineering groups and Plant Staff organizations including; Engineering, Maintenance, Procurement, Warehousing, Site Quality and Training.
o Overview. Engineering and Nuclear Safety (ENS) maintains the EQ Data Base and publishes it as EEQ-001, Electrical Equipment Qualification, and MEQ-001, Mechanical Equipment Qualification.
After review of the EQ qualification packages for required maintenance activities, ENS provides these requirements to the Maintenance Department as Equipment Qualification Maintenance Inputs (EQMI). The Maintenance Department reviews the EQMI's in accordance with procedure MD-1-007.
Any deviations between the
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- 6 ATTACHMENT B l-W3P86-0019 Sheet 4 of 5 EQMI's and the existing Preventive Maintenance Program are documented and transmitted to ENS for evaluation and resolution.
The resolutions are returned to maintenance for implementation.
Maintenance uses the EQMI's to prepare EQ Data Record Forms identifying EQ maintenance requirements to personnel working on EQ equipment.
These identify to the technician the EQ requirements for each piece of equipment.
In addition, the technician is able to verify and document EQ deficiencies as he '
is required to record the as-found and as-left conditions.
If deficiencies are fcund, they are documented and tracked until evaluated and resolved by Engineering. Data Record Forms are compiled fest all required EQ parts and equipment such as elastomers, lubricants, electrical and electronic equipment.
EQ mechanical equipment which is metallic, having a Qualified Life in excess of forty years, does not have nor does it require an EQ Data Record Form.
o Work Packages. Departmental Planners are required to use the MEQ-001 and EEQ-001 Lists prepared by ENS to make the determination of the EQ status of equipment for Condition Identification and Work Authorization (CIWA's). Applicable CIWA's are stamped EQ in red and an EQ Data Record Form is attached to the work package.
EQ preventive maintenance is identified in Work Program 6 in the PM tracking system. These tasks are printed out on yellow task cards denoting EQ. An EQ Data Record Form is attached as a part of the work package.
o Training. EQ training has been presented to onsite personnel including: Maintenance Engineering and selected individuals from various other Departments. The training included: one session each on "EQ Overview" for Engineering, Maintenance, and selected individuals, "EQ Maintenance" for Maintenance personnel, and "EQ Engineering Support" for Engineering personnel.
9.
Station Information Management System (SIMS): The SIMS program is presently being reviewed and modified to support our approved maintenance work flow.
Implementation is scheduled for the Fall of 1986. As a note of information:
o SIMS project is a multifaceted online, single data base concept to assist in the management of work during plant operations, as well as during outages. The system will help the plant to maximize its availability, and utilization of work forces at the highest level of productivity, by providing a systematic method for controlling work.
In addition, SIMS will serve as a major tool to enhance visibility with respect to safety-related component maintenance history and parts replacement traceabi14.ty.
SIMS is scheduled to be on line by late 1986.
10.
Material Management Information System (MMIS): MMIS is an inventory control system by which all departments of the company can, at any given time, determine the status of stock items, purchase requests, purchase orders. As a note of information:
- o ATTACHMENT B W3P86-0019 l
Sheet 5 of 5 o
The system when implemented will produce the necessary forms / paperwork needed in control of stock items. Additionally, l
the system will accumulate history data for automatic reorders, maintenance, and storage of stock items. To further strengthen our spare parts procurement program, the automatic reorder feature of MMIS will incorporate essential reorder information j
including up to date quality requirements for safety-related components.
l 11.
Organization changes:
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As mentioned earlier, a formal organization with authority that o
crosses normal organizational boundaries was set up under, an Engineering Support and Programs Supervisor. A chart of this new organization is attached. This ensures our ability to rapidly and effectively implement EQ activities and new information as it is developed by internal, industry and regulatory sources.
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An additional three Maintenance Engineers have been authorized allowing us to double our Maintenance Engineering staff. Efforts to fill our additional positions are in progress.
We intend to fill our recently vacated Site Quality Engineering o
Manager slot with a person knowledgeable and experienced in Maintenance. Site Quality Engineering now has the lead in site surveillance activities. We have a job offer out to a person knowledgeable in EQ. This individual previously held a job equivalent to our Maintenance Electrical Assistant Superintendent at an 1178MW PWR and also was Maintenance Superintendent at a 600MW coal burning plant.
In summary LP&L management is committed to a reliable and effective maintenance program.
Initiatives in work flow, work control, vendor l
information implementation, assistance from non-maintenance and non-plant L
organizations, worker knowledge and involvement in the Quality Control Program, Equipment Qualification. Station Information Management Systems, and Site Organization have been implemented or are underway. Necessary resources will be dedicated to ensure our commitments to effective maintenance will be met.
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