ML20204H481

Insp Rept 50-213/86-19 on 860707-11.Violation Noted:Failure to Properly Control & Document Maint Activities in Accordance w/quality-related Station Procedures

ML20204H481
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/29/1986
From:	Bissett P, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204H437	List: ML20204H432 ML20204H457 ML20204H481
References
50-213-86-19, NUDOCS 8608080126
Download: ML20204H481 (7)

See also: IR 05000213/1986019

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/86-19

Docket No. 50-213

License No. DPR-61

Licensee: Connecticut Yankee Atomic Power Company

P. O. Box 270

Hartford, Connecticut 06101

Facility Name: Haddam Neck Plant

Inspection At: Haddam Neck, Connecticut

Inspection Conducted: July 7 - 11, 1986

Inspectors: ,

L-Mi(seft', Reactor Engineer

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7 dat6

Approveu by-

J. Johnson, Chi 4f,

M1 7/79/F(

date

Operational Programs Section, 08, DRS

Inspection Summary: Routine Unannounced Inspection on July 7 - 11, 1986

(Report No. 50-213/86-19)

Area Inspected: Routine unannounced inspection of the maintenance program and

associated activities.

Results: One violation was identified: Failure to properly control and

document maintenance activities in accordance with quality-related station

procedures.

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DETAILS

1. Person Contacted

Connecticut Yankee Atomic Power Company

• W. Bartron, Maintenance Supervisor

• J. Beauchamp, QA/QC Supervisor

R. Caminati, Assistant Maintenance Supervisor (Electrical)

B. Danielson, I & C Supervisor

• J. Ferguson, Unit Superintendent

United States Nuclear Regulatory Commission

• P. Swetland, Senior Resident Inspector

S. Pindale, Resident Inspector

The inspector also held discussions with other licensee employees during

the course of the inspection.

• Denotes those present at the exit meeting on July 11, 1986.

2. Maintenance Organization

Maintenance activities are controlled and conducted by the Maintenance

and Instrument and Control (I & C) departments at Haddam Neck. The

mechanical and electrical groups make up the Maintenance department and

the I & C department is a separate entity. Both departments report to

the Unit Superintendent who has the overall responsibility for the conduct

of maintenance activities at the site.

3. Maintenance Activities

3.1 Administrative Controls

Administrative controls were reviewed to evaluate the licensee's

program for implementing requirements associated with preventive and

corrective safety-related maintenance activities. The objectives

were to assure that the licensee programs were consistent with the

Technical Specifications, Regulatory Guide 1.33, ANSI N18.7 and

Appendix B of 10 CFR 50. Documents reviewed are listed in Attachment

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3.2 Program Review / Implementation

The inspector held discussions with Maintenance and I & C department

personnel to evaluate those controls in place used to identify,

schedule, track, perform and document both preventive and corrective

maintenance activities. All maintenance activities are controlled

via an automated work order (AWO) which is part of the Production

Maintenance Management System (PMMS). PMMS is a computerized main-

tenance information retrieval system which provides a mechanism for

organizing and controlling maintenance activities, including job

scheduling, follow-up, documentation, etc.

The inspector reviewed the records of both random and selected main-

tenance activities performed on safety-related equipment to verify

the following:

Required administrative approvals were obtained prior to initi-

ation of work activities;

Appropriate approved procedures, instructions and/or drawings

were used;

Appropriate post maintenance testing was completed prior to

returning equipment to operation;

Hold points were appropriately identified and completed;

Qualified test equipment and tools used were identified;

Procedures and appropriate data sheets were properly completed;

Acceptance criteria were met;

Records were assembled, stored, and retrievable as part of the  !

maintenance history; and,

Appropriate reviews were completed as required.

Frequently, throughout the inspection, the inspector attended the

plant status morning meeting and the newly instituted department

level planned activity meeting. The department level planned act-

ivity meeting takes place each morning immediately following the

plant status meeting. This daily meeting was instituted to improve

communications and coordination between all departments on site in

reference to maintenance activities scheduled to take place that day

and the following day.

Personnel in attendance included first line supervision and PMMS

coordinators representing Operations, Maintenance (mechanical /elec-

trical), I & C, Health Physics, Betterment and Construction, and QA.

Since this week had marked the beginning of this regularly scheduled

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meeting, opinions were mixed as to its usefulness. However, the

general consensus was that it should improva their coordination of

activities where several departments might be involved. This should,

in turn, decrease the amount of time it often takes to get things

accomplished due to other departments not being well informed. The

inspector noted that personnel participation was very good.

During this inspection period, the licensee encountered problems with

the 'A' charging pump. Motor and pump display functions were indi-

cating erratic amperage and low discharge pressures. Upon further

investigation, it was discovered that the pump's shaft had sheared.

This has been a continuing problem with their 13 stage centrifugal

pumps. 'A' charging pump was taken out-of-service and the 'B' charg-

ing pump was placed on line. With only one charging pump available,

this action placed the licensee in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LC0 situation. Work

immediately commenced on the disassembly and repair of the 'A' charg-

ing pump under AWO CY-86-08584 and 86-08585 respectively. This work

activity was followed by both the region-based and resident inspec-

tor. NRC observation of this maintenance activity verified that the

following was accomplished:

Work activity was authorized as required;

An approved, up-to-date procedure was used throughout the main-

tenance activity;

The procedure was adequately detailed;

Operational personnel were notified prior to commencement of

work;

Applicable T.S. LCOs were identified;

Properly specified parts and materials were identified for the

activity;

Calibrated test equipment was used; and

Appropriate radiological precautions were taken, as necessary.

Further difficulties encountered during the reassembly of ' A' charg-

ing pump forced the licensee to commence a controlled plant shutdown

when it became evident that the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LC0 limit would be exceeded.

The resident inspectors continued to follow the licensee's actions in

this area.

3.3 Findings

On March 3, 1986, the licensee completed relugging all terminations

within CH-MOV-298. The inspectors' review of this maintenance acti-

vity indicated that the manner in which this activity had been com-

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pleted was not in accordance with plant administrative control pro-

cedures.

AWO CY-86-03247 was initiated on February 22, 1986 to relug termin-

ation to wire No. R-298 of CH-MOV-298. The improper crimping of the

respective lug had been identified by QA during the testing of CH-

MOV-298. However, upon further investigation, it was determined that

the improperly crimped lug had been incorrectly identified by QA. It

was found that the termination to wire No. Cl-298, not wire R-298,

had been improperly crimped. Further investigation also revealed

that all of the lead wires had been terminated using the wrong size

lugs. It was then decided to relug all the wires to CH-MOV-298, thus

expanding the scope of the original AWO. ACP 1.2-5.1, PMMS Trouble

Reporting System and Automated Work Order, requires initiating a

supplemental AWO when the scope of work increases. The relugging of

all lead wires to MOV-298 was eventually completed, however, a sup-

plemental AWO was never initiated. By not initiating the supple-

mental AWO, QC was not notified of the work until after the job was

complete (QC reviews all safety-related AW0s prior to initiation of

work, thus enabling them to insert QC inspection hold points.) All

lifted leads were later verified by QC of having been properly re-

connected. Also, AWO CY-86-03247 was classified as a Category 1,

Environmentally Qualified work activity, yet the Material Issue List

(MIL) denoted non-QA termination lugs as being used. ACP 1.2-2.5

Classifying and Upgrading Spare Parts, denotes specific criteria in

which material may be classified as commercial quality (non-QA). In

this particular instance, material issued should have been classified

on the MIL as Category I. The lugs in question were later determined

to be QA qualified lugs. The above two examples of failure to follow

procedures have been collectively categorized as a violation (213/

86-19-01).

During the review of in process and completed work packages, the in-

spector expressed some concerns over the manner in which the AW0s and

accompanying documents were completed. These concerns, brought to

the attention of plant management, included the following:

Lack of detail when completing " actual work / remarks / parts used"

and "cause of problem" sections;

Legibility of handwriting; and

Correctness of dates.

The licensee acknowledged the inspector's concerns and stated that

they were aware of the need for improvement in this area. Efforts

were underway and would continue to bring about the desired results.

The inspector had no further questions.

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4. Quality Assurance / Quality Control Interface-(QA/QC)

QA/QC is represented on-site, thus enabling this independent group to

actively monitor daily station activities. The inspector held discussions

with the site QC Supervisor and QA/QC personnel to ascertain their in-

volvement with site maintenance activities. QC reviews all safety-related

AWO's for identification of quality-related aspects prior to initiation of

a work activity. QA/QC also performs a final review of the work package

upon completion of the work activity to verify completeness prior to for-

warding to records for permanent storage. Detailed checklists are util-

ized during this review to ensure that all program and work activities

have been completed as required.

Recently, the QA group instituted an " activity surveillance" program,

which is oesigned to provide a quick 65servation of an activity without

all of the formalities normally associated with audits or monitors. The

actual conduct of a surveillance, identification of problem areas, and

resultant notification of responsible station management is expected to

take but a couple of days. Resolution of findings and resultant correct-

ive action is also expected to have a quick turn-around time. Activity-

surveillances can quickly apprise management of quality-related problems

or potential problems.

The inspector reviewed the most recently completed NUSCO (Corporate) QA

Audit A60228-Maintenance Activities. Several findings were identified,

many of which dealt with completeness and " attention to detail" when

completing AW0's. These findings coincided with those concerns identified

by the inspector as noted in paragraph 3.3.

QA also regularly attends morning meetings, both plant and departmental,

to maintain an awareness of ongoing work activities and any changes there-

of that may have occurred.

5. Management Meetings

The inspector met with the licensee representatives (denoted in paragraph

's) on July 11, 1986 to summarize the purpose, scope, and findings of the

inspection.

At no time during the inspection was written material provided to the

licensee by the inspector.

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ATTACHMENT 1

Documents Reviewed

Administrative Control Procedure (ACP) is 1.03, Connecticut Yankee Organ-

ization, Responsibility, and Authority, Rev. 3, 5/30/86.

ACP 1.2 - 2.1, Material, Equipment and Parts List for In-Service Nuclear

Generation Facilities, Rev. 10, 1/15/86.

ACP 1.2 - 2.4, Housekeeping Requirements, Rev. 10, 1/8/86.

ACP 1.2 - 2.5, Classifying and Upgrading Spare Parts, Rev. 3, 4/26/85.

ACP 1.2 - 5.1, PMMS Reporting System and Automat 9< Work Order, Rev. 27,

5/13/86.

ACP 1.2 - 10.1, Installation Inspections, Rev. 10, 5/14/86.

ACP 1.2 - 11.4, Product Acceptance Tests, Rev. 7, 3/10/86.

ACP 1.2 - 11.5, QA Activity Surveillance, Rev. 8, 12/7/84.

ACP 1.2 - 14.2, Equipment Control (Locking and Tagging), Rev. 7, 2/27/86.

ACP 1.2 - 16.1, Plant Information Report, Rev. 16, 1/16/86.

ADM 1.1 - 142, Plant Preventive Maintenance Program, Rev. O, 2/1/86.

ADM 1.1 - 145, Guidelines for Nuclear Plant Maintenance Activities, Rev. O,

2/1/86.

PMP 9.2, Preventive Maintenance Program (I&C), Rev. 3, 11/21/85.