ML20151W535: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
 
(One intermediate revision by the same user not shown)
Line 1: Line 1:
{{Adams
#REDIRECT [[PY-CEI-NRR-0845, Responds to NRC Re Violations Noted in Insp Rept 50-440/87-25.Corrective Actions:Preventive Maint Deferral Evaluation/Justification Sheet Will Be Formally Incorporated Into Procedures IAP-0501 & PAP-0906 by 880630]]
| number = ML20151W535
| issue date = 04/29/1988
| title = Responds to NRC 880331 Ltr Re Violations Noted in Insp Rept 50-440/87-25.Corrective Actions:Preventive Maint Deferral Evaluation/Justification Sheet Will Be Formally Incorporated Into Procedures IAP-0501 & PAP-0906 by 880630
| author name = Kaplan A
| author affiliation = CLEVELAND ELECTRIC ILLUMINATING CO.
| addressee name =
| addressee affiliation = NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
| docket = 05000440
| license number =
| contact person =
| document report number = PY-CEI-NRR-0845, PY-CEI-NRR-845, NUDOCS 8805030419
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 10
}}
 
=Text=
{{#Wiki_filter:.
      <  THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P.O. BOX 97    e  PERRY. OHIO 44081 e  TELEPHONE (216) 259-3737  e ADDR E S S - 10 CENTER ROAO Serving The Best L.ocation in the Nation PERRY NUCLEAR POWER PLANT Al Kaplan
(((($,                                            April 29, 1983 PY-CEI/NRR-0845 L U.S. Nuclear Regulatory Cocmrission Document Control De sk Washington, D. C.      20555 Perry Nuclear Power Plant Docket No. 50-440 Response to Notice of Violation 50-440/87025-03
 
==Dear Gentlemen:==
 
This letter acknowledges receipt of the Notice of Violation contained within Inspection Report 50-440/87025 dated March 31, 1988. The report identified areas examined by Mr. W. Kropp and others during their inspection conducted f rom January 11, 1988 through February 9,1988 of activities at the Perry Nuclea r Power Plant, Unit 1.
Our response to Notice of Violation 50-440/87025-03 is attached. Please call should you have any additional questions.
Very tru y yours, n H1,        uubv w                                    l Al Kaplan Vice President                                              ;
Nuclear Group                                                j AK: cab l
At tac hme nt ec:    T. Colburn K. Connaughton H. Miller - USNRC, Region 111 f
g9 8805030419 880429 PDR      ADOCK 05000440 0                      PDR
 
Attachment PY-CEI/NRR-0845 L Page 1 of 9 50-440/87025-03 Restatement of Violation 10 CFR 50, Appendix B, Criterion V, as implamented by PNPP, Operational Quality Assurance Plan, Section 5.0, requires that activities affecting quality be prescribed by instructions or procedures and accomplished in accordance with those instructions or procedures. Section 5.0 further requires procedures to include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above:
A. Procedure PAP-0906, "Control of Maintenance Section Preventive Maintenance," Revision 1, did not include criteria to make technical evaluations for rescheduling preventive maintenance activities. As a result, repetitive tasks (preventive maintenance) already several months past due, vere rescheduled for nine motor-operated valves in the residual heat removal and liquid radvaste systems without evaluations of the effects the delays could have on plant safety, operability, or reliability. (440/87025-03B)
B. The licensee failed to fully accomplish Preventive Maintenance Instruction, PHI-0030, "Maintenance of Limitorque Valve Operators,"
Revision 1, as follows:
o    The inspector observed that valve stems for several residual heat removal system and liquid radvaste system valves vere lubricated with Neolube although PMI-0030 specified Nebula EPO.
o    There vas no objective evidence that two residual heat removal system valves had been electrically and manually cycled as specified in the post maintenance requirements of PM1'-0030.  (440/87025-03C)
C. The licensee failed to properly implement Administrative Procedure PAP-0905, "Vork Order Process," Revision 7, which outlined the requirements for processing vork orders (V0) from initiation to closure as follows:
o    V0 87-9677 - Summary description did not accurately reflect the activity performed; o    V0 87-5727, 87-10390, 88-0080 - Incomplete or incorrect corrective action indicated on VO Closing and Summary Sheet; o    VO 87-6175, 87-7385, 87-8746, 87-9361, 87-9498, 87-9677, 87-10213 -
Incorrect or inadequate immediate failure cause identified on the VO Closing and Summary Sheet;
 
      -                                              A      Attachmtnt PY-CEI/NRR-0845 L Page 2 of 9 o  VO 87-2249, 87-8746, 87-9361, 87-9677, 87-10390 - Incorrect or incomplete V0 closing codes; o  VO 87 4925, 87-8298, 87-8597, 87-9677 - Incorrect or incomplete Master-Part List (HPL) npmbers; and o  VO 87-9361 - Inadequate closing summary on the V0 Closing and Summary Sheet. (440/87025-03A)
D. The licensee failed to fully accomplish Nuclear Quality Assurance Department procedure, NOAD 1840, Revision 2, "Audit Performance," Section 6.2, which required that deficiencies noted during audits be documented on Action Requests. Deficiencies identified during Audit 87-12, "Effectiveness of Corrective Action" vere listed as observations; therefore, the established corrective system was bypassed. One-observation pertained to continued untimely and ineffective corrective action, which prior to Audit 87-12, had also been identified as a concern by the licensee's OA organization and the NRC.      (440/87025-03D)
This is a Severity Level IV violation (Supplement I).
Corrective Action Taken and Results Achieved A. Failure to document technical evaluations for rescheduling preventive maintenance activities.
CEI agrees that PAP-0906 did not specifically include criteria to make the technical evaluations nor require documentation of the evaluations.
However, system engineers involved in rescheduling repetitive tasks have used engineering judgment, verbal instructions from unit leads, and/or informal desk-guide type instructions when performing this activity. The issue is not whether technical evaluations vere performed for rescheduled repetitive tasks, but whether this evaluation was documented. In order to allow for documentation of the technical evaluation, a Preventive Haintenance Deferral Evaluation / Justification Sheet has been developed and is being incorporated into the appropriate repetitive task procedures.
This form provides for a documented "Justification for Reschedule" and        ,
    "Effect on Component / Consequences of Non-performance" for safety-related  j repetitive tasks. Also, informal desk-guide instructions are being            !
developed which vill provide the system engineer with a list of appropriate questions to ask when considering approval or denial for rescheduling of a task. The form and the desk-guide instructions vill provide consistent documented technical justification of approval or denial for rescheduling of safety-related repetitive tasks.
 
Attachm:nt PY-CEI/NRR-0845 L Page 3 of 9 B. Several examples were identified of failure to fully accomplish Preventive Maintenance in accordance with PMI-0030.
: 1. The inspectors observed incunsistencies in valve stem lubrication.
CEI agrees that inconsistencies existed among the as-found conditions as well as the procedures and instructions which control the lubrication of these valve stems. As a result of these inconsistencies, procedures have been revised and training has been performed for maintenance personnel involved in this activity. These inconsistencies vere also evaluated as described below. An engineering evaluation was performed to determine the significance of valve stems lubricated with Neolube instead of Nebula EPO. The conclusion was that all of the valve stems identified vere adequately lubricated in accordance with vendor recommendations. However, improvements in lubrication practices should be made. The vendor of these valves recommends Neolube as an acceptable valve stem lubricant.
Neolube is a graphite type lubricant that dries upon application to the stem, leaving a fine dry graphite film coating.                              In cases where only Neolube exists on the valve stems, it should be recognized that PMI-0030 did not require stem lubrication if the existing lubrication was determined to be sufficient. Additionally, for MOVATS testing cf these valves per General Engineering Instruction (GEI)-0056, Neolube was utilized as the valve stem lubricant.                In cases where both Neolube and Nebula EPO exist on the valve stem, i t is possible that lubrication with Nebula EPO was deemed necessary during a performance of PHI-0030. This PHI did not require cleaning of the stem before applying lubrication, thus potentially resulting in both Neolube and Nebula EP0 being present. An engineering evaluation of the compatibility of the two lubricants determined that mixing of the two lubricants vill have no' deleterious effect on the valve or its operability. For the case where PMI-0030 did not require lubrication of the MOV upper bearing, a review of the vendor recommendations determined that the upper bearing should be lubricated periodically, resulting in a change to PMI-0030 on January 29, 1988.
The following procedure changes and training have been completed.
PMI-0030 as revised January 29, 1988 and GEI-0056 vas revised January 28, 1988 to be consistent in future lubrication activities.                                    For future Rockwell Hermaseal valve stem lubrication, Nebula EPO vill be used. For future stem lubrication of rising stem gate and globe valves, Never-Seez vill be used. Never-Seez is a lubricant that leaves a vet film coating which does not dry upon application.
Mobilgrease 28 vill be used in limit switch gear boxes, and Nebula EPO vill be used on operator main housings and upper bearing grease fittings. Also, the instructions now require that when a valve stem needs to be relubricated, it shall first be thoroughly cleaned and inspected prior to relubrication. Appropriate maintenance workers have been trained to these changes.
                                                  -.___.._.____.______--___---_. vee          --
                                                                                                    =-9  .-T-eiT--F W "'
 
k Attachment PY-CEI/NRR-0845.L Page 4 of 9 4
: 2. The inspectors found ne objective evidence of valve cycling af ter performance of PHI-0030. Research into the work history of the subject RHR . valves determined that the valves have been cycled since the performance of the PHI. This was performed on January 9, 1988 in accordance with the periodic-Technical Specification surveillance to verify opetability, and no problems were experienced. PHI-0030'has been revised (effective April 29, 1988) to specifylthat the, Control Room Unit Supervisor shall establish retest requirements. A further revision to PHI-0030 vill provide for documentation _of. retest completion.
f C. .Several examples were identified of inadequate and/or incomplete documentation during the review of' completed V0s.
: 1. V0 87-9677:    Summary description did not accurately reflect the activity performed.
This VO was performed to troubleshoot and repair a Residual Heat Removal (RHR) pump.not initiating on high heat exchanger level as expected. The cause of this problem was determined to be a level transmitter lE12-N008A being out of calibration. The corrective actions taken with the VO vere recalibration of the transmitter and a circuit loop check. The closing' summary as stated on the VO Closing and Summary Sheet was, "Recalibrated transmitter and loop checked Sat." PAP-0905 in section 6.7, Vork Order Package Closeout, requires the planner or vork supervisor to "...vrite a short, concise summary statement of the work actually performed..." Ve believe the requirement of PAP-0905 was met and the summary descript          did accurately reflect the activity performed. The only enhancement that could be made to the summary would be to include the transmitter HPL number. Fovever, this HPL number was adequately reflected on the same Closing and Summary Sheet vithin the corrective action summary description.
i
: 2. VO 87-5727, 87-10390, 88-0080: Incomplete or incorrect corrective action indicated on VO Closing and Summary Sheet..
: a. VO 87-5727 is still in the planning stages; no work has been performed on this V0; and thus, no Closing and Summary Sheet has been nor should have been complete for this V0. Ve believe that the VO number should have been 87-5722 in your inspection report.
The V0 Closing and Summary Sheet for this VO initially stated in the corrective action summary, "All work completed per the job traveler; change out and H0 VATS per NR PPDS-2554". This'was deemed insufficient and was revised to "Replaced Limitorque operator with rebuilt spare, performed H0 VATS on actuator per
  ;                      GEI-0056, adjusted torque svitch per SCR 1-87-1576, and installed new limiter plate". This change has been incorporated into the PPHIS history file for this V0.
4
 
Attachment PY-CEI/NRR-0845 L Page 5 of 9
: b. VO 87-10390 vas performed to troubleshoot intermittent relay problems in the Feedvater Control circuitry and to change three relays as directed by Design Change Package (DCP) 87-807. The VO Closing and Summary Sheet initially stated in ti corrective action summary, "Implemented DCP 87-0807".      This was deemed insufficient and was revised to, "Replaced existing time delay relays with Potter-Brumfield relays per DCP 87-807. Calibrated relays and obtained voltage readings for operating point of PDU output switch. Cleaned contacts and calibrated associated relays in control panel". This change has been incorporated into the PPMIS history file for this V0.
: c. VO 88-0080 was performed to replace the charge for the Standby Liquid Control squib valve per Surveillarice Instruction (SVI)-C41-T2002. During the performance of this VO power indication problema were observed. Troubleshooting of the circuitry identified two blown fuses which were promptly replaced.
The VO Closing and Summary Sheet corrective action summary initially only described the squib valve charge replacement. This was deemed insufficient and was revised to include the circuitry troubleshooting and replacement of identified blown fuses. Thir change has been incorporated into the PPHIS history file for chis V0.
: 3. VO 87-6175, 87-7385, 87-8745, 87-9361, 87-9498, 87-9677, 87-10213:
Incorrect or inadequate immediate failure cause identified on the V0 Closing and Summary Sheet.
: a. VO 87-6175 was performed to modify the stem and manufacture a new stem nut for valve lE12-F0024A in accordance with DCP 87-463. The V0 Closing and Summary Sheet initially stated in the immediate failure cause summary, "Modification of valve stem". This was deemed incorrect and was evised to "N/A" since the VO vas only implementing a design change. This change has been incorporated into the PPHIS history file for this V0.
: b. VO 87-7385 facilitated the mechanical portion of vork required to implement DCP 87-162A, which replaced the 1E22-C0004A diesel engine with an electric motor.      The V0 Closing and Summary Sheet initially stated in the immediate failure cause summary, "Replace diesel engine (Petter diesel) due to diesel failure". This was deemed incorrect and was revised to "N/A" since the VO vas only implementing a design change. This change has been incorporated into the PPMIS history file for this V0.
: c. V0 87-8746 vas performed to troubleshoot and repair the Division II Diesel Generator due to the field not flashing. The VO Closing and Summary Sheet initially stated in the immediate failute cause summary, "Diesel vould not field flash". This was deemed incorrect and was revised to "Unable to identify /unknovn" since the troubleshooting failed to identify any problems. This change has been incorporated into the PPHIS history file for this V0.
 
Attachment PY-CEI/NRR-0845 L Page 6 of 9
: d. VO 87-9361 was performed to troubleshoot and repair a leak from a snubber located above an RHR pressure transmitter 1E12-N0050B.
The VO Closing and Summary Sheet initially stated in the immediate failure cause summary, "steam leak at snubber". This was deemed insufficient and was revised to "Instrumentation tubing connection leaking. Loose connection" since the problem was identified as a loose tubing connection. This change has been incorporated into the PPMIS history file for this V0.
: e. VO 87-9498 was performed to troubleshoot a Division II Diesel Generator failure to start during the performance of SVI-R43-T1318. The VO Closing and Summary sheet initially stated in the immediate failure cause summary, "Diesel Div. II did not see pneumatic start". This was deemed insufficient and was revised to "Not identified - Suspect solenoid start valves 1R43-F0037B and F0030B" since the troubleshooting failed to pinpoint the cause. This change has been incorporated into the PPMIS history file for this V0.
: f. V0 87-9677 vas performed to troubleshoot and repair incorrect level indication for a RHR heat exchanger. The V0 Closing and Summary Sheet initially stated in the immediate failure cause summary, "RHR HX A level indication is low". This was deemed insufficient and was revised to "Level transmitter 1E12-N0008A out of calibration" since the calibration problem is the cause which vould be utilized in Failure Analysis trending. This change has been incorporated into the PPMIS history file for this V0.
I
: g. V0 87-10213 vas performed to repair bad connectors for two LPRMs reading downscale. The VO Closing and Summary Sheet states in the immediate failure cause summary, "Bad connectors". This vas deemed adequate since the problem was dovnscale LPRMs ael Une immediate cause was bad connectors. Identification (: 0. emisa of bad connectors vould be part of the root cause evaluation as part of the Failure Analysis program and is thus outside the scope or requirements of PAP-0905.                                      I
: 4. V0 87-2249, 87-8746, 87-9361, 87-9677, 87-10390:      Incorrect or      j incomplete V0 closing codes.                                            '
i The ineffectiveness of VO closing codes was identified by CEl during the INPO Maintenance Self Assessment which was completed in November    l of 1987. These codes were initially designed to aid in failure          '
analysis. However, due to recommendations provided from the Failure Analysis committee and the ongoing developnent of the Reliability      )
Information Tracking System (RITS), the decision was made to eliminate  I many of these PPMIS closing codes from the PAP-0905 vork order process. The failure analysis program needs vill be better supplied through a centralized evaluation of the existing VO closing summaries.
l
 
Attachm:nt PY-CEI/NRR-0845 L Page 7 of 9
: 5. VO 87-4825, 87-8298, 87-8597, 87-9677:    Incorrect or incomplete Master Part List (HPL) numbers.
The concern over HPL numbers chosen during VO initiation was identified by CEI during a QA audit report PIO 87-12, "Effectiveness of Corrective Action", issued July 29, 1987. PAP-0905 states that Vos should, when practical, address only one HPL number, and that single HPL numbers need not be addressed on Vos written to fill and vent instrumentation, for troubleshooting, or on standing V0s.
: a. VO 87-4825 was written to determine the cause of a Reuter-Stokes      i indexer failure. The MPL number utilized to open this VO was          !
                                      "N/A" since the indexer was not installed in the plant and thus had no HPL number. This indexer was removed from the field and replaced with a new indexer on Harch 26, 1987 in accordance with VO 87-2620. The MPL number used for V0 87-2620 was 1C51-J0002C        l and the failure cause vas identified es "unknown, VO 87-4825 vritten to troubleshoot failed indexer". VO 87-4825 could not have had a HPL number assigned to a salvaged component no longer installed in the field. However, to ensure identification of this V0 during future trending or failure analysis, the work summary specified the MPL number of the component when it was installed in    !
the field and also referenced VO 87-2620 as the VO vhich              )
originally removed the component from the field. Therefore, we        i believe that this VO vas written properly and is not an example of a violation.
: b. V0 87-8298 vas written to troubleshoot a contact failure to open on relay lE12-K42. The HPL number utilized to open this VO vas the system HPL lE12. The Plant Equipment Master-file System (PEMS) which ties into PPHIS to provide equipment data based on the HPL number input, does not contain HPL numbers for relays.
Therefore, the identification number for this relay could not have been used as the V0 initiating HPL number. However, to ensure identification of this VO during future trending or failure analysis, the work summary specified the problem as a relay lE12-K42 failure to open. Therefore, ve believe that this VO was written properly and is not an example of a violation,
: c. V0 87-8597 vas written to troubleshoot a lov temperature indication for the Division I Diesel Generator lube oil. Since the problem had not yet been identified, the HPL number utilized to open this VO vas the DG lube oil system HPL 1R47. If a specific component vere to be identified as the problem, the only way to change the MPL number would be to void the V0 and then open a nev V0 vith that HPL number. Nonetheless, troubleshooting failed to identify any problems. For future trending or failure analysis the suspected trouble components are vell documented throughout this V0. Therefore, we believe that this VO vas written properly and is not an example of a violation.
 
t Attachssnt PY-CEI/NRR-0845 L Page 8 of 9 f
: d. VO 87-9677'vas written to troubleshoot and. repair incorrect level  I indication for a RHR heat exchanger. Since the problem was suspected to be the controller 1E12-R0604A, this HPL number was utilized to open this V0. Troubleshooting identified the level transmitter 1E12-N0008A as~being out of calibration. Again, the only way to change a V0 initiation HPL number is to void the VO and then open a new V0 vith the new HPL number. Since this is not required and extremely inefficient, this vill not be done.
However, to ensure identification of the V0 during future trending or failure analysis, the corrective action identified in the Closing and Summary Sheet specifies the required recalibration of level transmitter 1E12-N0008A. Therefore, we believe that this VO vas written properly and is not an example of a violation.
: 6. V0 87-9361:  Inadequate closing summary on the VO Closing and Summary Sheet.
This VO vas performed to trmibleshoot and repair'a leak from a snubber located above an RHR pressure transtaitter 1E12-N0050B. The VO Closing and Summary Sheet initially stated in the cl< ming summary, "No leakage anymore". This was deemed insufficient and was revised to "Revorked      ,
tubing fitting with reactor seal #5" since this was the actual work'      ,
required to correct the problem. This change has been incorporated into the PPHIS history file for this V0.
l D. The concerns identified in Audit PIO 87-12 vere listed as observations because they were subjective and related to ef fectiveness of implementation of the corrective action programs as opposed to compliance with the procedures. The Quality Assurance procedure, NOADI-1840,-
requires that each deficiency be documented on an Action Request (AR).
As indicated in your report, our audit progcam has become more "performance related". The audit found compliance with the program to be adequate but the deficiency noted was "performance related". The line which separates deficiencies from improved performance is not vell defined and is open to interpretation resulting in this deficiency being.
documented as a recommendation rather than an IR.      As for your identifiec example, the audit organization has re-evaluated the effectiveness'of the Condition Report program and noted an improvement in both number open and mean time for closure of Condition Reporta. This improvement was partially due to actions taken as a result of the-recommendations in Audit PIO 87-12.
Corrective Action To Avoid Further Violations A. The Preventive Maintenance Deferral Evaluation / Justification Sheet as discussed previously will be formally incorporated into IAP-0501 and PAP-0906, for Instrumentation and Control Section and Maintenance Section respectively, by June 30, 1988. The guidelines for performing a proper technical evaluation for rescheduling repetitive tasks vill be provided to the appropriate engineers by May 30, 1988.
 
4 Attachment PY-CEI/NRR-0845 L Page 9 of_9 B. 1.      As discussed _previously, procedure changes relative to the valve.                  ,
lubrications vere completed January 29, 1988. Training for                          i appropriate maintenance personnel to these procedure changes has also been completed.
: 2.      The previously discussed revision to PMI-.0030 to provide for documentation of retest completion vill'be complete by Hay _ 20, 1988.
C. To ensure that the intent of the requirements of PAP-0905 is adequately met, the following corrective actions _have been or vill be. implemented.                    -
: 1.      Training is being provided to work supervisors and planners emphasizing their VO review responsibilities and the importance of providing adequate summaries on the V0 Closing and Summary. Sheet.
This effort vill be complete by May 31, 1988.
i
: 2.      A Reliability Information Tracking System (RITS) is being implemented                !
manually and vill be fully computerized by April 30, 1989. The objective of this program is to analyze component failures, and. based on the results, recommend corrective actions to prevent recurrence.
As a result of this program, changes are being made to PAP-0905, Vork Order Process.
: a. A Program Change Request (PCR) has been initiated to provide a                  }
section on.the VO Closing and Summary Sheet for MPL numbers of all              i affected equipment. This vill ensure a greater capture percentage when trending for failure analysis or planning a VO on a                        i particular mmponent. This PCR vill be complete by                              l November 30, 1988.                                                              I
: b. PAP-0905 was revised (effective March 1, 1988)~to eliminate the need for the work groups to determine "Failure Category" and "Cause of Failure" closing codes. The RITS program vill utilize the summaries within the VO package to consistently determine VO closing codes for trending purposes when deemed necessary.
D. To ensure that the interpretation between deficiency and improved performance is made conservatively, OA guidelines have been revised to-clarify the threshold for issuing ARs to include not only-programmatic I
deficiencies or noncompliance, but also significant deficiencies which affect the effective implementation of processes. Appropriate QA personnel vere trained to this change April 29, 1988.
Date of Full Compliance Full compliance vill be achieved upon full implementation of RITS by                                j April 30, 1989.
l m -            . _      .    ._            ..~-- ~ ..-, ,_. _ -
_ _ ,_ _            - , _ - ,--._,i}}

Latest revision as of 12:55, 22 July 2023

Redirect to:

Retrieved from "https://kanterella.com/w/index.php?title=ML20151W535&oldid=3581977"