IR 05000327/1986048

Insp Repts 50-327/86-48 & 50-328/86-48 on 860908-12. Deviation Noted:Failure to Prepare Quarterly Employee Performance Repts

ML20214G177
Person / Time
Site:	Sequoyah
Issue date:	11/13/1986
From:	Falconer D, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214G169	List: IR 05000327/1986048 ML20214G166 ML20214G174
References
50-327-86-48, 50-328-86-48, NUDOCS 8611250605
Download: ML20214G177 (22)

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M K82 UNITED STATES

1. #o NUCLEAR REGULATORY COMMISSION

[' n REGION 11 g j 101 MARIETTA STREET, * * ATLANTA. GEORGI A 30323

'+9 * . . . + ,o Report Nos.: 50-327/86-48 and 50-328/86-48 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: Sep mb r -12, Lead Inspect,or: A / //[f r v'

A D. P.' Falconer Date Signed Inspectors: F. R. McCoy C. L. Vanderdniet Accompanying Personnel: R W. Cooper, IE:HQ Approved by: . i % I 13 $

B. Wilson, Acting Section Chief Date' Signed Operational Programs Section Division of Reactor Safety SUMMARY Scope: This special, announced inspection was conducted in the area of maintenanc Results: One deviation was identified; Failure to prepare quarterly Employee Performance Reports - see paragraph 7.f.

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PDR ADOCK 05000327 G PDR l

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REPORT DETAILS

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, Persons Contacted Licensee Employees

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• P. R. Wallace, Plant Manager

• Z. M. Kabiri, Site Services Manager

• D. C. Craven, QA Manager

"B. M. Patterson, Maintenance Superintendent ,

• R. W. Olson, Modifications Manager

• M. R. Harding, Site Licensing Manager

• G. B. Kirk, Compliance Licensing Supervisor l *H. D. Elkins, Instrument Maintenance Supervisor M. A. Skarzinski, Electrical Maintenance Supervisor 4 "G. S. Boles, Mechanical Maintenance Engineering Supervisor

• L. S. Bryant, Mechanical Maintenance Engineering Supervisor

• R. K. Gladney, Instrument Engineer Supervisor

• R. M. Mooney, Systems Engineer Section Supervisor t

• T. Traffanstedt, Planning

• D. H. Tullis, Special Projects

• R. C. Birchell, Licensing Engineer

• A. Purcell, Licensing Engineer Other licensee employees contacted included engineers, technicians,

mechanics, and office personnel.

NRC Resident Inspectors i K. Jenison

• P. Harmon D. Loveless

• Attended exit interview i Exit Interview The inspection scope and findings were summarized on September 12, 1986,

with those persons indicated in paragraph 1 above. The inspector described

the areas inspected and discussed in detail the inspection findings. No l dissenting comments were received from the licensee. The licensee did not identify as proprietary any information reviewed by the inspectors.

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The status of maintenance items identified in inspection reports 327,328/85-45 and 327,328/86-18 were provided to the licensee as follows:

(Closed) IFI 327,328/85-45-01 (Closed)IFI 327,328/86-18-01 (Closed)IFI 327,328/85-45-02 (Closed) IFI 327,328/86-18-02 (0 pen) IFI 327,328/85-45-05 (Closed)IFI 327,328/86-18-03 (0 pen) VIO 327,328/85-45-06 (Closed) IFI 327,328/86-18-04 (Closed VIO 327,328/85-45-09 (0 pen) IFI 327,328/86-18-05 (Closed IFI 327,328/85-45-10 (0 pen) IFI 327,328/86-18-06 (Closed IFI 327,328/85-45-15 (0 pen) UNR 327,328/86-18-07 (0 pen) UNR 327,328/85-45-17 (0 pen) UNR 327,328/85-45-18 The following new items were noted as baing opened during this inspectio Items requiring completion prior to restart were identified to the license Deviation 327,328/86-48-01: Failure to perform quarterly employee performance evaluations in the mechanical maintenance section as specified in the Revised Sequoyah Nuclear Performance Pla IFI 327,328/86-48-02: Implementation of the Technical Support Systems Engineering Sectio IFI 327,328/86-48-03: Complete the evaluation of the detailed review of Technical Specifications and FSAR for preventative maintenance (PM)

requirements not addressed in the current PM program prior to restar .

UNR 327,328/86-48-04: Plant Operations Review Section evaluation of out of calibration measuring and test equipment (M&TE).

IFI 327,328/86-48-05: Complete restart maintenance action identified during the review of potential reportable occurrences (PRO) issued between January 1,1984 and December 31, 1985, prior to restar . Licensee Actions on Previous Enforcement Matters (0 pen) VIO 327,328/86-45-06: Failure to Take Adequate and Timely Corrective Actio Example a: Failure to promptly correct problems with completing engineering and quality assurance reviews of field completed main-

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tenance request In response to the violation, the licensee stated that increased priority has been placed on evaluating 670 maintenance requests (MRs)

identified as lost with 432 still requiring evaluation, that Sequoyah maintenance procedure SQM-2 was revised to clearly define MR routing and maintain better status of tracking, that computer changes would be made to implement the improved MR status tracking program, and that various personnel would receive training on their responsibilities in this area. A review of SQM-2, Revision 19, portions of the MR tracking

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system data base, and training attendance records for maintenance procedures SQM-2, SQM-58, and work request status tracking computer

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classes reflect that committed actions have been completed. Review of an interoffice memorandum from the Maintenance Superintendent date May 19, 1986 and interviews with various maintenance personnel

(including the individual assigned responsibility for resolving this problem) indicate increased priority in reducing the existing backlog,

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evaluating and resolving lost MRs, and in processing field completed  !

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MRs within a reasonable time frame. A review of current data reflects that of the original 670 MRs identified as lost which were field completed prior to February 18, 1983, 365 still required dispositio Of these 365, 216 were determined by the licensee to be in quality assurance revie Review of tracking systep data reflects progress in  ;

minimizing review time of recently field completed MRs. Based on the l completion of committed actions and the progress made to date in reducing this backlog, this portion of the violation is considered closed.

Example b: Failura to correct repetitive out of calibration occur- t i rences on the upper head injection (UHI) level switche The corrective actions as stated in the licensee's responses, dated March 20 and June 27, 1986, appeared to be satisfactory to preclude

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similar-problems. The trending program being developed to identify

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adverse trends of out of calibration and component failures indicates i that repetitive.out of calibrations will be identified and evaluated in

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' Concerns regarding the licensee's inadequate evaluations of past repetitive failures and out of calibrations under the former trending

program, and the submittal of a supplemental response to this violation

detailing the new trending program, will be followed and documented by

the resident inspection staf This portion of the violation remains

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ope ; (Closed) VIO 327,328/85-45-09: Three examples of failure to properly

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implement procedures in the areas of improperly rewiring a motor operated valve, failing to consider vendor recommendations associated with auxiliary control air dryer preventative maintenance, and deficient housekeeping practices.

l Review of work request package 101569 (MR A295497), temporary change -

t 85-1668 to work plan 11853, work plan 11866, and modifications group memorandum dated September 9,1986, reflected satisfactory completion of committed actions with respect to the valve rewiring proble Review of SQM 57, Revision 5, administrative instruction AI-23, Revision 22, OSLA-99, surveillance instruction SI-689, and NRC Inspection Report (50-327,328/86-18), reflected satisfactory completion of committed actions with respect to the auxiliary control air dryer preventative maintenance problem. With respect to deficient house-keeping practices, NRC Inspection Report (50-327,328/86-18) reflected l

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adequate and improved housekeeping in previously identified deficient areas. Additionally, the licensee's "P2" schedule for restart reflects scheduling control for a final restart housekeeping inspection and cleaning evolution. These factors satisfactorily complete committed actions with respect to deficient housekeeping practices. Violation (327,328/85-45-09) is considered close c. (0 pen) UNR 327,328/85-45-1': Operability of the UHI System in Light of Repeated Out of Technical Specification Tolerance Calibration Result The licensee's evaluation of past out of calibration data, dated May 12, 1986, indicated that one level switch in each upper head injection (UHI) flow path was found calibrated such that UHI isolation would have occurred above the Technical Specification allowable cetpoint tolerance during an event. The early isolation of UHI would have resulted in less than the analyzed volumetric delivery of the UHI system. In each case, upon discovery, the licensee recalibrated the level switch to within the required tolerance prior to exceeding the Technical Specification LC In addition to the UHI level switch out of calibrations, the resident inspection staff identified that during the same time period, there were repetitive failures of the UHI isolation valves to meet stroke time criteri In that the stroke times could potentially impact the operability of the UHI system, the licensee was requested to reevaluate UHI operability considering the level switch calibration and stroke time data concurrentl These concerns will be followed by the resident inspection staff and fully documented in their monthly inspection repor d. (0 pen) UNR 327,328/85-45-18: Provide Complete Description of Corrective Actions Taken to Preclude Circumstances which Resulted in the Installation of UHI Level Switches with Incorrect QA Level

Designation The licensee has corrected the procurement process to preclude the procurement and installation of class 1E components without the appropriate seismic qualification documentatio According to the licensee, all class 1E replacement components currently in power stores that do not have appropriate seismic documentation have been identi-

! fied, segregated and appropriately tagged to preclude future use in i

class 1E applications. Approximately 125,000 maintenance requests were reviewed to identify all class 1E replacement mild environment components in this categor Resolution of potential qualification problems concerning the 138 components involved is anticipated to take six month To establish the extent of the seismic qualification problem, the licensee identified a smaller representative sample of 50 replacement class 1E components without required seismic documentation and

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contacted the vendors concerning qualification. Of the 50 components

< only one required actual additional qualification testing by the vendor. The others required only evaluation and documentation of their seismic qualificatio Ongoing resolution of the 138 components currently installed in the plant without the appropriate seismic qualification documentation will be followed by the resident inspection staf (0 pen) Unresolved Item 327,328/86-18-07: Lack of Documentation Supporting Completion of Vendor Recommended Maintenance on Seven Pump Subassemblies Listed in PM 0909-31 The licensee was able to provide documentation in the form of AI-36

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data sheets and PM 1051-317 that fully described the extent of preventative maintenance performed on the seven pump subassemblies listed in PM 0909-317. Review of this information reflected several discrepancies and concerns concerning preventative maintenance of stored components some of which may be generic in nature. Specifically:

(1) Of the seven pump assemblies referenced in the PM, two of the assemblies are no longer in stock and three are not CSSC com-ponents (#3 heater drain pump, #7 beater drain ' pump, stator

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cooling water pump)

(2) For the two safety related pum;. elements which are in stock (Turbine Driven Auxiliary Feedwater Pump element and Safety Injection Pump element), the PM package requires completion of AI-36, paragraph 5.11.20. This paragraph states that storage of turbine, pump, and compressor rotors require consideration on an individual basi In general, it requires special damage protection, corrosion protection, and periodic rotation. They may

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l be shipped in various condition Contact the purchasing source or cognizant maintenance engineer or his representative for specific instruction The mechanical maintenance engineering supervisor stated that his interviews with technicians performing this activity reflected that the inspection, as performed, simply verifies that storage boxes for the elements are in the designated storage are (3) The vendor's manual for the AFW pump element does not provide any specific guidance with respect to maintenance or care of a pump element during storage and reflects that the pump element should be protected from unfavorable weather.

[ (4) The vendor's manual for Safety Injection internal pump element has very specific guidance for storage and maintenance during storage for this internal pump element which are not reflected in the preventative maintenance program.

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(5) AI-36, Attachment 2, provided for a power stores general inspection record for each storage area and PM 0909-317 required a storage inspection for packaged pump elements in storage. The elements of inspection were not compatible with one another in all cases and since packages are not opened for inspection, some elements of inspection such as rust, corrosion, and surface contamination are not really inspected when the AI-36 sheet indicates these as inspection elements. Although the PM 0909-317 sheet indicated that packaged elements need only be inspected for integrity of packaging, the mechanical maintenance engineering i supervisor indicated that this PM had been cancelled since it was redundant with AI-36 requirements and AI-36 would control these inspection element The inspectors consider that the licensee's program for preventative J maintenance of components in storage shows indication of inconsistent requirements in licensee prepared documents. Additionally, the inspectors consider that the use of vendor source documents in establishing storage and maintenance requirements for stored components

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appears to be insufficien The inspectors also consider that this problem may be generic in nature requiring programmatic resolution.

This unresolved item remains open pending resolution of'these concerns.

l Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. One new unresolved item identified during this inspection is

! discussed in paragraph UNR 327,328/86-48-04: Evaluation of out-of-calibration measuring and test equipment (M&TE). General Assessments and Conclusions The inspection team considers that the licensee has accomplished an overall improvement in the Sequoyah Maintenance Program through the implementation of the Revised Sequoyah Nuclear Performance Plan. Management attentinn in the area of maintenance has been extensive and aggressive with the dedication of significant resources to the resolution of deficiencie Weaknesses identified in Inspection Reports (327,328/85-45) and (327, 328/86-18) have, for the most part, been formally evaluated and resolved by the license Further effort is required in the improvement of the preventative program, particularly in the establishment of base line requirements and the implementation of these requirements into preventative maintenance packages. The licensee's effort in this area entails the review of the preventative maintenance program against the FSAR and Technical Specifications should be completed prior to restart, and has been identified I as inspector followup item (327,328/86-48-03).

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Although an overall improvement was noted, several additional areas were identified in which the licensee should direct management attention to ensure timely and thorough resolutio These areas included the following: The identification of potentially unreliable plant components which may not have been previously identified due to deficiencies in the former maintenance trending progra This concern will be followed by the resident inspection staf The operability of the UHI system in light of excessive level switch out of calibrations and failures to meet isolation valve stroke time This concern will be followed by the resident inspection staff.

The resolution of seismic qualification concerns regarding installed class 1E replacement components. This concern will be followed by the resident inspection staf The completion of the ten maintenance actions identified in the licensee's review of potential reportable occurrence These maintenance items should be completed before restart and have been identified as inspector followup item (327,328/86-48-05).

6. Review of Maintenance Inspector Followup Items (Closed) IFI 327,328/85-45-01: Licensee Review of All Outstanding Maintenance Requests (MRs), Design Change Requests (DCRs), and Engineering Change Notices (ECNs) and Interview of Engineers to Determine and Resolve Questionable Operability Concerns with Safety Related Equipmen NRC Inspection Report (327,328/86-18) noted that required actions with respect to MRs were considered complete and that only the review of design change requests (DCRs) and engineering change notices (ECNs)

still applie Interviews with Engineering Department personnel, and review of the licensee's Base Line Verification Program reflected that the scope of review encompassed by this inspector followup item for DCRs and ECNs is not within the envelope of the base line verification j program and consequently that verification process does not resolve this concern. The inspectors noted, however, that the licensee had conducted a review of PR0s issued between January 1, 1984 and December 31, 1985, for potential cauipment operability concerns and ten maintenance actions were designated, for completion prior to r,estart as identified in inspector followup item (327,328/86-48-05). Additionally, resolution of concerns regarding the licensee's inadequate evaluations of past repetitive failures and out of calibration conditions, as identified in Violation (327,328/85-45-06), is considered to appro-priately encompass the operability concerns that would be generated from a review of outstanding design packages. Consequently, this item may be administratively closed since it is redundant with Violation (85-45-06) and IFI (86-48-05).

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b. (Closed) IFI 327,328/85-45-02: Replace Barton Model 288A Differential Pressure Switches on Unit 2 UHI Syste Initial installation and testing of the replacement Static "0" Ring (SOR) differential pressure switches was completed in March 1986. On August 28, 1986, the SOR switches were removed under work plan 11907 and returned to the vendor for modification and recertification in response to problems identified in IE Bulletin 86-02. The licensee anticipates delivery from the vendor by September 13, 1986, and reinstallation the following wee The reinstallation and testing of the vendor modified SOR switches will be followed under IE Bulletin 86-02. This item is close c. (0 pen) IFI 327,328/85-45-05: Review Completion of MRs Identified as Requiring Completion Prior to Unit Restar NRC Inspection Report (327,328/86-18) noted that of the listed MRs, only three had not yet been completed; MRs A536974, AS46226, and A521756. A review of records reflected that MR AS46226 had been field completed on June 17, 1986 and that QA review of this MR had been completed on July 17, 1986. Additionally, MR A536974 was noted to have been field completed and tested on May 2,1986 and QA review of this MR was in progres With regard to MR A521756, which was initially written to resolve problems with motor operated valve clutch trippers, it was noted that the MR was ctncelled and work was reestablished as a modification package via Category D Field Change Request (FCR) 4267, ECN L6697, and Work Plan 12089. Work Plan 12089 was noted to have been field completed on August 4, 1986; however, the work plan only accomplished modification of six of the ten valves identified on the ECN. The valves which were not modified were valves 1-63-01, 2-63-01, 1-72-20, 1-72-23. The licensee stated that two of the valves would not

require modification since they were passive and deenergized valves, l and that the other two valves were not required to be modified since l their actuators were replaced with a different type during the Unit 1 l Environmental Qualification (EQ) Modification Program.

l At the exit interview, the licensee provided copies of a partial modification completion form and unreviewed safety question deter-mination (USQD) form which had been approved by the Plant Operations Review Committee (PORC) that da The inspectors consider that there was insufficient information included in the USQD to determine the

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acceptability of the partial modification and question how PORC members

! could have approved this partial modification based solely on this i information. Resolution of this item is pending further discussion of I the acceptability of the licensee's USQ d. (Closed) IFI 327,328/85-45-10: Completion of Corrective Actions Associated with Self Identification and Correction of Inadequacies in Approval of Administrative Instructions.

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Review of NRC Inspection Report (50-327,328/86-18), LER (1-85-048), and a memorandum from PORC subcommittee to the plant manager dated August 13, 1986, reflect that an LER has been issued on this problem, procedures specifically identified by the NRC have been PORC approved, and an evaluation conducted which identified 12 additional standard practice procedures that require PORC approval. Additionally, this same evaluation forwarded an additional 45 comments on standard practice procedures for resolution. Although all action is not completed with regard to resolving the PORC subcommittee comments noted in this evaluation, the inspectors determined that action has been assigned to the site procedures staff to provide for PORC approval of requisite documents and to resolve PORC subcommittee comment This assignment was being adequately tracked through the licensee's management action tracking system as Item S53 9155. These actions taken to date are considered satisfactory for closure of this ite e. (Closed) IFI 327,328/85-45-15: Ensure that All Applicable Personnel Have Received Training as Stated in the Sequoyah Nuclear Performance Plan, Paragraph 4.1 The inspection team had previously noted that the licensee was in the process of determining which engineers missed unreviewed safety question determination (USQD) training. The inspector reviewed attendance lists and memoranda sent to all plant sections requesting lists of individuals in need of USQD trainin Retraining of approximately 137 engineers was accomplished during July and August 1986. Currently, six individuals who were not previously available for the training remain to be trained. Based on the licensee completing the training of a substantial number of the individuals who previously missed USQD training, this item is considered close f. (Closed) IFI 327, 328/86-18-01: Evaluate Other Plant Applications of the Barton Model 288A Differential Pressure Switc Unresolved Safety Question Determination (USQD) 86-21 evaluated all safety related and compliance applications of the Barton Model 288A differential pressure switc This evaluation identified several applications with unreliable calibration results over their calibration interval In addition to the UHI application, the following applications were identified for switch replacement under DCR 2157 prior to the restart of Units 1 and 2:

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Flow Indication Switch FIS-68-7, 30, 49 & 72, low RTD manifold flow alarm will be replaced. The indication function of the Barton 288A will remain in servic FIS-74-12 & 24, RHR mini-flow recirculation valve control will be replaced.

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The following switches were determined to have calibration drift problems but will not be replaced prior to restart. Adjustments in their calibration programs, with Plant Operations Review Staff (PORS)

assessment, have been identified as a commitment tracking item to ensure reliable system operatio *

(1) 0-LIS-39-36: The indication portion of this switch is used to verify the CO2 tank level in the diesel generator building as required by SR 4.7.11. To provide additional confidence in this presently installed switch, the licensee plans to perform a calibration verification on a three-month cycle initiall The data will be reviewed by the PORS Assessment Section, and the calibration interval can be changed commensurate with the calibration performanc The licensee has initiated a request under DCR 2157 to replace this switch when appropriate materials and manpower are availabl (2) 0-LS-313-305 and 340: These switches have experienced moderate calibration shifts during previous performances. The deviations have not been severe and did not cause the system to be inoper-able; however, they do show a trend of deviations that require corrective measure The licensee plans to decrease the calibration schedule for this switch to a six-month interval. The calibration data will be reviewed by the P0RS Assessment Section and the calibration in erval may be changed commensurate with the calibration performanc (3) 1 and 2-FIS-70-81: These switches exhibit a condition of repeated out-of-tolerance condition. The licensee has determined that the out-of-tolerance condition does not appear to have resulted in an inoperability of the function (which is to transfer from the running to the non-running thermal barrier booster pump on a low flow condition). To assure proper operation of these switches, the licensee plans to reduce the calibration interval to three month The calibration data will be reviewed by the PORS Assessment Section and the calibration interval may be changed commensurate with the calibration performar c (4) 1 and 2-PDIS-67-490/491-A/B, B/A, C/D and D/C: The control function on these switches has been deleted under TACF numbers 83-0004-67 and 83-2001-67 for units 1 and 2, respectivel :

Permanent changes will be implemented on ECN 551 (5) 1 and 2-PDIS-67-490/491-E/F and F/E: These switches provide a control function to backwash the essential raw cooling water (ERCW) strainers when the differential pressure is greater than 6 PSI The E/F function on these switches is for alarm onl , There has been some recorded calibration shifts; however, they are not large and the licensee has determined that it does not effect

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safe operatio The F/E side of the function has shown some

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tendency to shift calibration between scheduled test The

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licensee's review of the history records have shown that the drift is normally in the conservative direction (lower differential pressure condition). The ERCW has been analyzed to provide sufficient flow with a strainer in backwash. To add assurance, the licensee plans to reduce the calibration frequency on these switches to a six-month interval. The data collected will be reviewed by the P0RS Assessment Section and the calibration interval may be changed commensurate with the calibration performanc Based on the licensee's implementation of these corrective actions, this item is close g. (Closed) IFI 327, 328/86-18-02: Incorporation of a Precaution Noting that Open and Closed Torque Switch Settings are Located Opposite the Open and Close Terminals for SMB-000 and Old Style SMB-000 Limitorque Valve Actuator A review of draft Revision 4 to MI-10.43 reflected actions initiated to incorporate this precaution as a note to step 6.2 of the procedur Revision 4 is expected to be issued prior to October 1986 and is considered sufficient for closure of the ite h. (Closed) IFI 327, 328/86-18-03: Development of a Formal Change Process for Non 10 CFR 50.49 Equipment Preventative Maintenance Package A review of SQM-57 reflected that the change process of SQM-57 related to 10 CFR 50.49 equipment covers delaying PM performance beyond the 25%

frequency or cancelling the PM. This is done in accordance with Attachment The inspectors consider this appropriate and note that a form similar to Attachment 3 will be transferred from SQM-57 directly into SQM-62. The new SQM-62 form will provide for evaluation of source recommendations for implementation into preventative maintenance packages for 10 CFR 50.49 equipment, as well as for cancelling or '

extending performance frequency beyond 25%.

In the case of non 10 CFR 50.49 equipment, the inspectors consider that the licensee's current provision that the Maintenance Group Supervisor or Maintenance Engineering Section Supervisor approve frequency I extensions beyond 25% and cancellations is adequat This item is considered close . (Closed) IFI 327, 328/86-18-04: Trending Out of Calibration Dat The inspector reviewed a draft revision to SQM-58 which fully incorpcrates out of calibration data in the licensee's current trending l

progra The trending program appears to be adequate for the identification of adverse trends of potential component failures. This i system involves the trending of both the Equipment Information System l (EQIS) and the Nuclear Plant Reliability Data System (NPRDS) data bases. The inspector reviewed the licensee's semi-annual Component l Failure Trending Report, dated June 9, 1986, which covers the period l

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January 1, 1985 through December 31, 1985. The report appeared to be a comprehensive assessment of NPRDS data for unidentified unreliable components through trend analysi The licensee's plans for the development of a staff devoted to the trending of component failures, if fully implemented, will provide adequate component trending and failure assessmen The licensee's complete description of the trending program will be included in a supplemental response to Violation (327, 328/85-45-06). This item.is close j. (0 pen) IFI 327, 328/86-18-05: Update Applicable Procedures to Specify Torque Switch Settings for Applicable Motor Operated Valves (MOVs).

Engineering is currently evaluating torque switch settings for all MOV This item will remain open until administraive controls are established for specified torque switch setting k. (0 pen) IFI 327, 328/86-18-06: Review of Maintenance Instruction (MI)

Rewrite Progra The inspector determined that progress on the MI Rewrite Program has been attained; however, no MI rewrite had been processed through final PORC review at the time of this inspection. Therefore, a conclusive final review of rewri tten mis could not be accomplished by the inspection tea The inspector noted the completion of the prioritization of all electrical and mechanical mis, including the 17 new mis identified by this IF The prioritization of mis provided a means of selecting which mis were to be completed prior to the July 30, 1987 (priority 1)

date stated in Sequoyah Nuclear Performance Plan (SNPP) II.4.2, Maintenance Instruction (MI) Enhancement, and those that will be completed later (priority 2). A completion date for rewrite of all priority 2 mis is to be determined by September 29, 1986, and all priority 2 mis will be validated for useability during their next performance. The prioritization considered the following criteria as weight factors for determining priority placement of each MI:

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Craft formal training on equipment

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Complexity of task

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Consequence of error

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- Number of additional documents required

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CSSC equipment or Tech Spec / Reg. Guide requirement

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Frequency of performance Mechanical and electrical mis with a total weight factor greater than 35 were given priority This resulted in a total of 68 mechanical mis and 16 electrical mis to be completed prior to July 30, 198 . -

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During the review of the prioritization list, the inspector compared those instructions listed with the listing of all active mi The inspector noted approximately 12 mis that were not included in the prioritization process. The licensee could not provide justification for the omission of these mis, and informed the inspector that they would determine the reasons for the omission Generic mis covering a widely related field of components such as valves, were also prioritized. These mis will also be reduced in size and scope by writing new mis to cover specific types of component The entire MI rewrite program will be accomplished in accordance with the Writer's Guide contained in Appendix B of SQM1, Revision The inspectors conducted a walkdown of MI-8.7.1, Maintenance Guidelines for Traveling Water Screens, and MI-10.10.1, Disassembly / Reassembly Guic 'ines for ERCW Screen Wash Pumps to determine the adequacy of the lict .ee's development of 17 new maintenance procedures. The walk-through determined that, although these procedures were written prior to the implementation of the Writer's Guide, they were adequate to accomplish the specified maintenance tasks until rewrites could be accomplishe The Writer's Guide is a detailed description of the format, organiza-tion, and writing style to be used in the rewr . ing of all mis. The guide appears to be well developed and structured and should improve the quality and uniformity of the licensee's current mis. The addition of the guide, checklist and revisions to SQM1 will reduce the vagueness of procedures, and provide a good standard philosophy for MI constructio The inspector reviewed two newly rewritten mis which are currently in the review stage to determine if they were developed pursuant to the Writer's Guide. Both mis appeared to be written as the Writer's Guide directed with only one minor deviation noted concerning an overuse of

! logic terms as specified in SQM1. The inspector considers that the

, highlighted logic terms were used too often and, in some cases, l inappropriately which may result in reducing the importance intended.

l Both mis had been clearly reviewed by several individuals as evidenced

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by corrections written throughout the body of the procedures.

l The MI review process is aided through the use of a detailed 11-page MI I evaluation checklis The checklist contains detailed questions l concerning all portions of the MI, and follows the format of the mis l making it even more effective. The MI review process includes a craft review, quality assurance review, initial PORC review by management l staff, and a final PORC review. At present, these reviews should be

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sufficient to ensure the correctness of the mis, providing the review process scope is not reduced due to increasing workloads and approaching deadline Especially important in the review of a procedure is the walkthrough to determine if the written MI will

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actually wor This walkthrough is completed during the validation phase and is the final quality check on the procedure The licensee is currently using Westinghouse contractors to perform the rewrite of the mis, and plans to reinforce these efforts through the additional use of facility electrical and mechanical engineers and crafts persons. The utilization of facility personnel in the develop-ment process is encouraged to ensure the technical and operational correctness of the rewritten mi This item will remain open until the licensee has progressed sufficiently in the maintenance instruction enhancement program to determine the adequacy of maintenance instruction rewrite . Implementation of the Nuclear Performance Plan The inspectors verified the implementation of selected portions of the Revised Sequoyah Nuclear Performance Plan (SNPP), Section 4.0, Maintenanc For the most part, the licensee has implemented improvements to the .

Maintenance Program as delineated in the Revised SNP Two areas were identified in which the licensee has deviated from the Plan. The licensee has discontinued quarterly employee performance evaluations in the Mechanical Maintenance Section, and has not performed timely out of calibration maintenance and test equipment (MT&E) evaluations as detailed in the items below. The following Revised SNPP items were reviewed by the inspectors: SNPP II.1.2.2, pg. II-6, Bullet #3: Permanent Craft Section supervisors have been named for each maintenance grou The inspectors interviewed the Maintenance Group Supervisors to confirm that permanent craft section supervisors have been named for each maintenance group. Each group supervisor, in discussing the advantages of this organizational change, stated that this has resulted in freeing the general foremen to become more involved in technical, day-to-day issues, and to spend more time in the field. Additionally, the craft i section supervisor can dedicate his time to administrative items and

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forward-looking programs and special projects. Each group supervisor indicated that this organizational change has improved the functioning of his group.

i SNPP 11.1.2.2, pg. II-6, Bullet #6: A general foreman has been added l

to the IM group, and management control of maintenance activities is I provided on backshift The inspector verified that the IM group has added a general foreman to l its organization. There are now two (2) IM general foremen who each supervise four (4) foremen and their respective crews. There is one foreman and crew on the evening shift, and one foreman and crew on the midnight shift. The IM group supervisor stated that this has solved the lack of communication that previously existed between the day shift and the backshift by providing for shift turnover between day shift and backshift foremen.

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This organization appears to effectively control backshift maintenance activitie SNPP II.4.1.1, pg. II-55, Bullet #1: A structured and routine schedule of supervisory meetings has been initiated in each maintenance grou The inspector discussed with each of the three maintenance group supervisors the meetings that they routinely conduct with their craft section supervisors, general foremen, and foremen. Although the frequency and times for each section's meetings differs to some extent, all are regularly scheduled and attended by the appropriate personne The inspector attended an Electrical Maintenance Section meeting. It was well formatted, well prepared for by all participants, and a free flow of information was noted. Performance, coordination, scheduling, assignments for problem resolution, plant policy issues, and administrative matters were discusse SNPP II .4.1.2, paragraph 2: Maintenance personnel have attended the two-day QA training cours The inspector reviewed course attendance records and confirmed that approximately 97 percent of maintenance craft personnel have attended this training. The attendance records reflect those individuals who either failed the course or, for some reason, did not complete it after starting i In the case of the single individual who failed the course, remedial training has been given in accordance with a section instruction lette In the case of seven craftsmen who have not completed the training, the licensee is taking action to ensure that these individuals receive the required trainin SNPP II.4.1.2, paragraph 2: Appropriate personnel have attended update trainin The inspector reviewed attendance records for this training and noted that three (3) foremen and one (1) planner had not attended the training. The licensee plans to conduct refresher training in the near future to cover changes and clarifications that are currently being made to SQM-2, and will ensure that all applicable individuals atten SNPP II .4.1.3, paragraph 1: Quarterly employee performance evalua-tions.

I The inspector verified that each of the maintenance sections had programs in place for employee performance reporting and conducting j quarterly evaluation sessions with foremen and general foremen. The

' inspector conducted a detailed review of the Mechanical Maintenance Section's program with the following results:

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The employee performance reports (EPRs) and quarterly evaluations I have been discontinued since February 1986. The Craft Section Supervisor is developing a performance indicator system to supplement the employee performance reporting program to make the program more meaningful. Although this idea has merit based on the draft performance indicators that the inspector reviewed, it is still in the developmental stage with no schedule for implementation. Therefore, the Mechanical Maintenance Section should continue to implement the program stated in the SNP *

In the majority of cases where disciplinary action was taken as a result of an EPR, the time period between the incident and completion of disciplinary action far exceeded (2-3 months in some cases) the stated target of two (2) weeks.

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• The quarterly evaluations of foremen were inconsistent with the EPRs applicable to them over the time period covered. For j

instance, one foreman was rated superior in the employee safety i and health area when all five of the EPRs-initiated on his crewmen during that period concerned employee injuries on the job. In

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another case -a foreman who had no EPRs initiated dur.ing the

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evaluation period was graded as average in every area of his evaluation, and it was specifically noted that he should place more emphasis on RWP adherence and personal safet In yet another case, a foreman who had received three above-average EPRs i

for his crew, was graded as average in seven of ten area Based on the above information, the licensee should reinstate the EPR program in the Mechanical Maintenance Section and evaluate its implementation in the entire Maintenance Section to ensure that the program is meeting its goals as stated in the SNPP. This item is a deviation (327, 328/86-48-01).

g. SNPP II.4.1.3, paragraph 3: Accountability of routine work in each maintenance group through assignments to a specific forema The inspector reviewed the specialization and surveillance instruction (SI) assignment lists for each of the three maintenance sections. The l Mechanical Maintenance Section has assigned each SI to the general foreman level. The Electrical Maintenance Section has specialized its crews by equipment type. The Instrument Maintenance Section has assigned most of the Technical Specification-related sis to its foremen. Although the SNPP stated that each SI in the Instrument Maintenance Group would be assigned to a foreman, the inspector considers that the assignment of major component and system sis to individual foremen will accomplish the objectives stated in the SNP h. SNPP II.4.1.4: New maintenance request system.

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The new Maintenance Request System in general appears to provide sufficient control of maintenance activitie Interviews with plant personnel indicated a potential problem with the implementation of the new syste Apparently, personnel are not properly placing and removing maintenance request tags upon the initiation and completion of work activitie The inspectors consider that management attention should be directed to the resolution of this deficiency in personnel compliance with the progra Interviews also identified a concern regarding the awareness levels of craft supervision and planners of recently implemented plant modifi-cations. These personnel are not routinely provided plant modification information and, on occasion, the lack of this information has impacted their ability to efficiently accomplish their job function The licensee should consider routinely providing these personnel with this informatio i. SNPP II.4.2.4, paragraphs 2 and 3: Guidelines provided to planners in determining post-maintenance test requirements and potentially inadequate MR package The inspector reviewed the guidelines provided to planners in determining post-maintenance test (PMT) requirements. These guidelines are part of SQM-2, " Maintenance Management System". They appear adequate for providing criteria for component functional tests as well as de. ferring testing to existing sis if functional tests are already included therei Discussions with planners indicated that their knowledge' of these guidelines was adequate and, that they appeared to value them as usefu Regarding guidelines for determining potentially inadequate MR packages, these guidelines have recently been promulgated in Revision 6 of SQM-1. The guidelines consist of a process flow chart, providing a step-by-step determination that has three possible results:

PORC-reviewed instruction required

' written instruction may be needed - decision deferred to appropriate supervisor

• no written procedure is needed Planners agree that this guideline will be useful in determining MR package requirements that will be acceptable to QA upon initial review, thereby decreasing the percentage of MR rejects by Q SNPP II.4.3.2, Bullet #2: Technical support systems engineering section implementatio . - . _ - -

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The inspector reviewed SQA-168, " System Engineering" and discussed implementation of the Technical Support Systems Engineering Section with the Systems Engineering Section Supervisor. The licensee intends to initiate the Systems Engineering Program in stages over a two year perio This is to facilitate the development of training and budgeting of manpower. Initially, walkdowns and trending techniques will be developed for the ERCW and RHR systems prior to startup of Unit 2. These techniques will be expanded to 14 safety-related systems one month after Unit 1 startup. After a more thorough training program and identification of engineering responsibilities and manpower requirements, the program will be expanded to the 33 safety-related systems covered by the Design Baseline and Verification Program to ensure that interface between this section and other related sections

are well defined, documented, and properly implemented. This item will be identified as inspector follosup item (327, 328/86-48-02) for subsequent inspection followu SNPP II.4.3.2, Bullet #4: Organizational changes to direct more management attention to the trending of equipment deficiencie The licensee plans to staff a Trending and Environmental Qualification Section within the Maintenance Group which will be responsible for the trending of NPRDS and EQIS data to identify unreliable components and equipmen Currently, only the manager of that section has been assigne Trending activities are being accomplished pursuant to SQM-58, " Maintenance History and Trending", with the initial develop-ment of sectional responsibilities and policies, and the establishment of management interfaces underway. Preliminary staffing plans indicate that the section will be composed of the following personnel; a section manager, an engineer, an engineering aide, three NPRDS aides, and two data entry clerk . SNPP II.4.3.2, Bullet #5: FSAR and the technical specification review l

for the inclusion of requirements and commitments in preventative l maintenance procedure The inspector reviewed the licensee's program for reviewing the Technical Specifications, FSAR, and the Critical Structures, Systems, and Components (CSSC) lists for recommended preventive maintenanc Each of the maintenance sections utilized their engineers to conduct these reviews. The methodology was as follows:

FSAR - applicable systems and segments of the FSAR were assigned within each section to be reviewed for statements regarding the conduct of preventive maintenance in accordance with vendor recommendations or normal industry practic Technical Specifications (TS) - reviewed by each maintenance section for preventive maintenance requirements (Instrumentation Section considered calibration and related activities as surveillance testing; thus, inclusion of all required calibration was considered part of the separate SI review program).

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• CSSC lists - each system and component was assessed as to determine whether preventive maintenance was needed, a procedure or program already existed for it, the existing procedure was adequate, a revised or new PM was needed for startup, and if a special PM was needed due to the extended shutdow Each of the maintenance sections has completed the three reviews described above. Each section has identified components for which maintenance is needed or stipulated in the FSAR or TS, but for which no preventive maintenance is currently performe The following is a partial list:

(1) Mechanical

FSAR gaseous and liquid waste, post accident sampling system HVAC, spent fuel pit cooling systems; TS - diesel generators;

• CSSC lists - not reviewed by the inspecto (2) Electrical FSAR - spent fuel pit cooling system, control rod drive equipment systems, and steam generator blowdown and ESF systems; TS - none; CSSC lists - approximately 196 pieces of rotating equipment (only CSSC equipment not covered under the QMDS program).

(3) Ir.strument - not available due to the draft nature of the results.

i The Mechanical Section's review appeared very comprehensive based on the volume of documentation that existed; the Electrical Section's review appeared comprehensive; the Instrument Section's review appeared to have received the least amount of documentation (a two page, handwritten, draf t report). Each section must now assess the findings

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where vendor recommendations should have been followed, assess the recommendations for implementation and document recommendations not implemented via a deficiency report in accordance with AI-2 assess whether a PM program should be implemented for equipment that was noted as having maintenance programs that conform to normal industry practic submit FSAR changes as necessar _

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Since some of the findings concern regulatory commitments for the performance of PM on equipment that is not currently under a PM program, the licensee should complete the assessment of the findings of the initial reviews and identify those PMs that must be implemented prior to startup. This item will be identified as inspector followup item (327, 328/86-48-03) for subsequent inspection followu m. SNPP II.4.3.4, Bullets #1, 2, & 3: Corrective actions to deficiencies in the measuring and test equipment (M&TE) progra The inspector reviewed the licensee's implementation of the SNPP plan to increase the timeliness of the performance of out-of-calibration (00C) investigations for M&TE. Per AI-31, " Control of Measuring and Test Equipment", the licensee is required to complete the evaluation of all new cases within an average cf 14 working days of receipt of the package on site, to include the identification of all equipment effected, a complete history search, and a safety evaluation if not completed within 10 working days. According to the Assessment Section Supervisor, Plant Operations Review Staff (PORS), the licensee implemented the AI-31 00C M&TE investigation requirements with ~ the June 1986 issuance of the PORC-approved procedure. A review of out-standing section evaluations of 00C M&TE since June 1986 reveals that many evaluations have exceeded the 14 day average timeframe for completion of review. The Supervisor, Procurement Contracts / Scheduling has issued memoranda to the sections with outstanding M&TE evaluations, with a copy to PORS requesting that the packages be sent to P0RS for the conduct of the required safety evaluation In no cases have any packages been forwarded to PORS for performance of the required safety evaluations. Neither PORS nor Procurement Contracts / Scheduling have been following up on this required actio When the plant becomes operational, the timely completion of 00C M&TE evaluations is necessary to ensure that nuclear safety is not compromised. Current indications are that the licensee's M&TE program is acceptable, but is not being properly implemented. Therefore, this item will be identified as unresolved (327, 328/86-48-04) pending the

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l prompt completion of PORS evaluation SNPP II.4.5, paragraph #3: Potential reportable occurrences (PRO)

initiated between January 1984 and December 1985 were reviewed to l

determine if the corrective maintenance performed was adequate to

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prevent recurrence The licensee's review identified ten items requiring additional action prior to restart. The status of corrective actions is as follows:

(1) WR B111606 to repair defective cable on a steam generator level l loop was completed on April 30, 198 (2) Arror Hart Contactors - PMs were written and performed to maintain the front mounted contacts - complete.

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(3) MOVs - All CSSC motor operated valves that are electrically operable will be MOVATS tested to improve reliability - in wor (4) CRDM Connectors - ECN 6405 was worked to eliminate pin problems by removing the connector and splicing the actual conductors -

complet (5) Replace D/G fuel oil pumps - Initiated and completed MRs to replace pumps and revised MI - complet (6) Lubricate auxiliary feedwater valve stems - Two PMs were written, 1487-003 and 1486-003, and performed March 3, 1986, and June 2, 1986 -

complet (7) Pressurizer instrumentation (PR0s 1-84-201, -310, -261, -394, -398,

-401, 2-85-02, -03, -05, -06) - ECN 6495 was issued. The portion of the ECN implemented during this outage will be to relocate 2LT-68-320, 2PT-68-322 and 323 outside the polar crane wall. This is for access during operation. Also, the root valves will be changed to a single valve to prevent water blockage of the steam interfac (8) Barton 288A switches and their plant functions - It was determined that the following switches would be replaced prior to unit 2 startup, FIS-74-12 and -24 (RHR Pump Minimum Flow Valve Switches). These switches were added to DCR 2157 which changes the RCS bypass manifold switch. This work is also scheduled for this perio (9) Backfill - Procedures are in process of being written and are about 75 percent complet All backfill procedures will be in place prior to startup of unit WR B111606 to repair defective cable on a steam generator level loop was cumpleted on April 30, 198 (10) Condenser vacuum exhaust flow monitor (PR0s 1-84-246, 2-84-111, and 1-84-233) - It was decided that this flow monitor should be replaced with a more reliable typ DCR 2023 was submitted on October 20, 1983, and ECN L6437 was issued. The flow monitors are from Fluid Components, Inc., and should be on site September 29, 198 These items should be completed prior to restart as determined by the licensee's evaluation (IFI 327,328/86-48-05).