ML20199K791

Insp Repts 50-321/86-08 & 50-366/86-08 on 860224-0303. Violations Noted:Failure to Implement Maint Controls, Document Conditions Adverse to Quality & Implement Existing Plant Procedures Properly

ML20199K791
Person / Time
Site:	Hatch
Issue date:	03/26/1986
From:	Poertner K, Schnebli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20199K763	List: ML20199K758 ML20199K775 ML20199K791
References
50-321-86-08, 50-321-86-8, 50-366-86-08, 50-366-86-8, NUDOCS 8604100229
Download: ML20199K791 (7)

See also: IR 05000321/1986008

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. A Kffog UNITED STATES

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NUCLEAR REGULATORY COMMISSION

REGION ll

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g' j 101 MARIETTA STREET, N.W.

• 's ATLANTA, GEORGI A 30323

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Report Nos.: 50-321/86-08 and 50-366/86-08 ,

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302

Docket Nos.: 50-321 and 50-366 License Nos.: DPR-5.7 and NPF-5 ',

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Facility Name: Hatch 1 and 2 -

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j Inspection Conducted: February 24 - March 3, 1986 '

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Inspectors: Ah bk11:

G. Seinebli

3/26 l86

Date Signed

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8 ,/M * At 3hd84

K. Poertner j Date Signed

Approved by: ef:24L MU

F. Jape, Section Chief (/ / Date Signed

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 120 inspector-hours at the

site, in a review of maintenance programs and practices.

Results: Two violations were identified - (1) Failure to implement maintenance

controls and document conditions adverse to quality - paragraph 5.a. (2) Failure

to implement existing plant procedures properly - paragraphs 5.b. and 5.c.

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9604100229 860404

PDR ADOCK 05000321 pnn

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

S. Barr, Maintenarce Supervisor

• S. Brunson, Reactor Systems Engineer

0. Fraser, Quality Assurance Audit Supervisor

• P. Fornel, Manager of Quality Assurance

R. Gatliff, Shift Supervisor

R. Glisson, Maintenance Engineering Supervisor

• C. Goodman, Regulatory Compliance Engineer

R. Houston, Quality Concerns Coordinator

R. Keck, Engineer Supervisor

T. King, Maintenance Foreman

D. McCusker, Superintendent of Quality Control

T. Metzler, Maintenance Engineer

• D. Morgan, Engineering Supervisor

• H. Nix, General Manager

• T. Powers, Manager of Engineering

• T. Seitz, Manager of Maintenance

• B. Thigpen, Quality Assurance Specialist

Other licensee employees contacted included outage craftsmen, engineers,

technicians, operators, mechanics, and office personnel.

NRC Resident Inspectors

• P. Holmes-Ray, Senior Resident Inspector

G. Nejfelt, Resident Inspector

• Attended exit interview

2. Exit Interview -

The inspection scope and findings were summarized on March 3,1986, with

those persons indicated in paragraph 1 above. The inspectors described the

areas inspected and discussed in detail the inspection findings. The

following new items were identified during this inspection:

Violation 321/86-08-01, Failure to implement maintenance controls and

document conditions adverse to quality - paragraph 5.a.

Violation 321/86-08-02, Failure to properly implement existing plant

procedures - paragraphs 5.b and 5.c.

Unresolved Item 321/86-08-03, Determine actual maintenance performed on

valve E11-F004B in 1981 - paragraph 5.d.

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l Proprietary material was reviewed during the course of this inspection,

i however, the information is not contained in this report.

3. Licensee Action on Previous Enforcement Matters

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This subject was not addressed in the inspection.

4. Unresolved Items

An unresolved Item is a matter about which more information is required to

i determine whether it is acceptable or may involve a violation or deviation.

t One new unresolved item identified during this inspection is discussed in

paragraph 5.d.

5. Review Of The Maintenance Program and Practices (62702)

This inspection was conducted to review the licensee's maintenance program

and maintenance practices in the area of valve repairs accomplished during

the current Unit 1 outa An in depth review of valve maintenance in the

Residual Heat Removal (ge.RHR) System was performed. In this inspection, the

following documents were reviewed:

50AC-MNT-001-05, Revision 4, Administrative Control Procedure -

Maintenance Program.

32GM.MEL-022-05, Revision 0, General Maintenance Procedure - Limitorque

Valve Operator Electrical Maintenance.

10AC-MGR04-0, Revision 0, Administrative Control Procedure - Deficiency

Control System.

40AC-ENG03-0, Revision 0, Administrative Control Procedure - Design

Control.

52CM-MME-011-OS, Revision 0, Corrective Maintenance Procedure - Gate

and Globe Valve Repair.

52-PM-MME-010-0, Revision 0, Preventive Maintenance Procedure - Safety

and Relief Valve Maintenance.

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! 50AC-MTL-002-05, Revision 1, Administrative Control Procedure -

Identification and Control of Material and Equipment.

40AC-QCX-001-0, Revision 0, Administrative Control Procedure - Quality

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Control Inspection Program

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42EN-ENG-009-0, Revision 2, Engineering Procedure - Equivalent Deter-

l mination of Replacement Parts or Materials.

Maintenance Work order (MW0),1-85-7214 - Work Performed on Valve

1E11-F0158.

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MW0, 1-85-7330 - Work Performed on Valve 1E11-F0178.

.. MWO, 1-85-7120 - Work Performed on Valve 1E11-F004A.

MWO, 1-85-7216 - Work Performed on Valve 1E11-F0308.

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MWO, 1-85-7019 - Work Performed on Valve 1E11-F007A.

MW0, 1-85-7118 - Work Performed on Valve 1E11-F028A.

MWO, 1-85-7672 - Work Performed on Valve 1E11-F025A.

MW0, 1-85-7119 - Work Performed en Valve IE11-F0078.

MW0, 1-86-0615 - Work Performed on Valve IE11-F0248.

MWO, 1-85-7215 - Work Performed on Valve 1E11-F0288.

MWO, 1-85-7217 - Work Performed on Valve IE11-TRV.

MWO, 1-81-3328 - Work Performed on Valve IE11-0048.

MW0, 1-86-0472 - Additional Work Performed on Valves 1E11-F028A and

1E11-F0288.

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MW0, 1-86-0987 - Additional Work Performed on Valves 1E11-F024A.

MWO, 1-86-1155 - Additional Work Performed on Valves 1E11-F004A.

In the review of the documents listed above, the following deficiencies were

noted:

a. Maintenance Work Order (MWO) 1-85-7120 was initiated to repair valve

1E11-F004A, RHR torus suction valve. During inspection of the

internals of the valve, it was determined that the valve wedge had to

be replaced and a replacement wedge was obtained from supply using

Purchase Order 7666. During assembly of the valve wedge to the valve

stem, it was determined that the replacement wedge did not fit the

original stem supplied with the E11-F004A valve. The valve stem had a

"T" head configuration whereas the wedge slot had an hourglass

configuration. The maintenance supervisor, a Crane Valve employee,

directed his maintenance personnel to grind down the valve stem to make

the replacement wedge fi t . The grindin'g of the valve stem was

accomplished on the verbal instructions of the maintenance supervisor

and was not documented in the work package reviewed by the inspectors.

Upon discovery by the licensee, efforts were made to obtain a replace-

ment stem with the hourglass design. The licensee was unable to obtain

a replacement stem with the hourglass design due to outage limitations

and delivery constraints, so Crane Valve Services contacted ALOYC0 who

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contacted Walworth, the valve manufacturer, with a proposal for a

! temporary fix to utilize the existing stem until the next available

outage when a proper stem replacement could be made. Walworth provided

a sketch to modify the "T" head stem arrangement to approximate the

hourglass stem arrangement that per the Hatch drawings should have been

installed in the valve. No attempt was made to determine why a "T"

head stem and wedge were originally installed in the valve, nor was a

design change request initiated to modify the existing stem.

l 10 CFR 50 Appendix B Criterion XVI states: Measures shall be estab-

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lished to assure that conditions adverse to quality such as failures,

j malfunctions, deficiencies, deviations, defective material and equip-

ment and nonconformance are promptly identified and corrected.

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10 CFR 50 Appendix B Criterion V states: Activities affectinJ 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. Instruc-

tions, procedures, or drawings shall include appropriate quantitative

or qualitative acceptance criteria for determining that important

activities have been satisfactorily accomplished.

Hatch procedure 10AC-MGR04-0, Deficiency Control System, step 8.2

states significant conditions adverse to quality will normally require

initiation of a Deficiency Report (DR). During the operations Phase of

plant Hatch, the conditions described in Attachment 1 shall be

considered Significant Conditions adverse to Quality.

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Attachment 1 of 10AC-MGR04-0 states that negligence or disregard of

management policy defined in administrative controls or procedural

requirements is a significant condition adverse to quality.

Contrary to the above, when it was determined that the replacement

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wedge for valve IE11-F004A did not fit the original stem, the stem was

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ground down to make the replacement wedge fit. This modification of

the original stem was accomplished on the verbal authorization of the

maintenance supervisor only. No deficiency report was initiated to

document that the replacement wedge did not correspond tn the as-found

condition of the valve or that modification of the original stem had

l been accomplished by disregarding the administrative controls and ,

j procedural requirements of the Hatch Maintenance program. This is )

identified as a Violation 50-321/86-08-01, Failure to implement main-

tenance controls and document conditions adverse to quality. Review

of this violation is continuing, therefore, it is not included in the

Notice of Violation.

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b. Maintenance Work Order 1-85-7217 worked the IE11-thermal relief valve

on the RHR side of the "B" RHR heat exchanger. The inspectors reviewed 1

the work package associated with this work and noted no discrepancies

in the paper work provided for review. Per the work package, the valve

had been removed, repaired, reinstalled and tested in accordance with

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l approved procedures. Review of the RHR Piping and Instrument Diagram

l determined that there are two thermal relief valves associated with the

RHR heat exchanger. One relief valve is located on the RHR side of the

heat exchanger and one relief valve is located on the RHR service water

side of the heat exchanger. The inspectors inspected both relief

valves. The RHR side relief valve did not appear to have been worked.

The RHR service water side relief valve appeared refurbished and had a

l valve leak repair yellow tag that referenced MWO 1-85-7217. When

informed by the inspectors that the wrong thermal relief valve had been

repaired by MWO 1-85-7217 the licensee verified that the thermal relief

valve on the RHR service water side of the "B" RHR Heat Exchanger had

been worked instead of the thermal relief valve located or. the RHR side

of the heat exchanger as required by MWO 1-85-7217.

Failure to properly implement the maintenance program as defined in

! Administrative Procedure 50AC-MNT-001-005, Maintenance Program is

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identified as a Violation 50-321/86-08-02, Failure to properly imple-

ment existing plant procedures.

c. Maintenance Work Order (MWO) 1-84-5742 worked the limitorque operator

on valve IE11-F1038, one of the RHR Heat exchanger vent valves. This

MWO required the perfomance of procedure 52GM-MEL-022-05, Limitorque

Valve Operator Electrical Maintenance. Section 7.9 of procedure

52GM-MEL-022-05 performs the preoperational set up and test of the

limitorque valve operator. Review of the completed work package

revealed that steps 7.9.13.7 through 7.9.13.17.1 were not performed

during the performance of procedure 52GM-MEL-022-05. Section 7.9.13

performs the Electrical Circuit test of the limitorque operator prior

to the operational test conducted in Section 10 of procedure

52GM-MEL-022-05.

Procedure 52GM-MEL-022-0S did not allow for the omission of steps

7.9.13.7 through 7.9.13.17.1.

Technical Specification 6.8.1 requires that written procedures be

established, implemented, and maintained covering maintenance and

surveillance activities. Failure to properly implement maintenance

procedure 52GM-MEL-022-OS is identified as another example of Violation

50-321/86-08-02.

d. Inspector Review of Maintenance History records showed that valve

1E11-F004B had its wedge replaced in 1981 by Maintenance Work Order

1-81-3328. Review of the work performed revealed that a replacement

wedge was obtained from the same purchase order used in the replacement

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of the wedge for the IE11-F004A valve. The inspectors expressed

concern that the same "T" head type stem may have been originally

installed in IE11-F0048. The MWO package did not identify a problem

between the stem and wedge fitup. This item is identified as

Unresolved Item 50-321/86-08-03 Determine actual maintenance performed

on valve E11-F004B in 1981, and must be resolved prior to Unit 1

startup.

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l Within the areas examined, two violations and one unrenlved item were

identified.

6. Management Meeting

On March 13, 1986, a management meeting was held between GPC,and the NRC in

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the Region II Office. The meeting was attended by senior GPC management,

Crane Company Management, and Region II Management and staff. The purpose

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of the meeting was to discuss the apparent lack of control in the valve

maintenance program, at Plant Hatch, based on the findings previously

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addr.cssed in this inspection report.

J. T. Beckham, Vice President and General Manager for Nuclear Generation,

opened the meeting for GPC by discussing their policies in regard to

Regulatory Requirements and Quality Assurance. Additional discussions were

introduced concerning GPC effort to increase the maintenance staff in order

to reduce the number of contract personnel currently required for mainte-

nance. In addition, Mr. Beckham, addressed the ongoing procedure upgrade

program. T. A. Seitz, Manager of Maintenance for Plant Hatch, lead the

discussion concerning GPC management systems which ensure quality work

and addressed the specific items of concern identified during this in-

I spection. Mr. Beckham then closed the meeting with a summary and

I indicated they would look further into the concerns identified in

the maintenance program.

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