ML20207G251

Insp Rept 50-458/86-06 on 860203-07 & 0303-07.Violation Noted:Failure to Have Procedures Requiring Incorporation of Vendor Technical Info in Maint Procedures

ML20207G251
Person / Time
Site:	River Bend
Issue date:	06/17/1986
From:	Boardman J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207G225	List: ML20207G220 ML20207G239 ML20207G251
References
50-458-86-06, 50-458-86-6, NUDOCS 8607220742
Download: ML20207G251 (18)

See also: IR 05000458/1986006

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-458/86-06 License: NPF-47

Docket: 50-458

Licensee: Gulf States Utilities Company

P. O. Box 220

St. Francisville, Louisiana 70775

Facility Name: River Bend Station

Inspection At: St. Francisville, Louisiana 70775

Inspection Conducted: February 3-7 and March 3-7, 1986

Inspector: M [. 4//7//4

g J. R. Boardman, Reactor Ihspector, Operations D4te '

7 Section

Accompanied

by: Luther Jones, EG&G

Howard Stromberg, EG&G

Dean Sumers, EG&G

Approved By: h$n)sbm$

D. M. HunnicutT., Chief, 9perations Section

/1/ryfr/4

Date '/ '

Inspection Summary

Inspection Conducted February 3-7 and March 3-7, 1986 (Report 50-458/86-06)

Areas Inspected: A Region IV routine, announced team inspection of licensee

maintenance activities was made, covering maintenance program, maintenance

program implementation, instrumentation and control (I&C) maintenance,

electrical maintenance, mechanical maintenance, and maintenance program QA.

Results: Within the six areas inspected, one violation was identified (failure

to have procedures for activities affecting quality). This violation included

several examples.

$IO $DNk $8

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DETAILS

1. Persons Contacted

• +W. J.' Cahill, Jr., Senior Vice President, River Bend Nuclear Group

• +J. C. Deddens, Vice President, River Bend Nuclear Group

• +T. L. Crouse, Manager, Quality Assurance

+W. H. Odell, Manager, Administration

• +R. W. Helmick, Director, Projects

> +W. J. Reed, Director, Nuclear Licensing

• +T. F. Plunket, Plant Manager

• +D. M. Reynerson, Director, Nuclear Plant Engineering

• +P. F. Tomlinson, Director, Quality Services

L. R. Cummings, Mechanical Maintenance Foreman

• J. D. Davis, QA Engineer

• +D. R. Derbonne, General Maintenance Supervisor

• +K. E. Suhrke, Manager, Projects Planning and Ccordination

+A. O. Fredieu, Assistant Operations Supervisor

• +E. R. Grant, Supervisor, Nuclear Licensing

J. L. Frick, Electrical Maintenance Foreman

• +J. R. Hamilton, Supervisor, NSSS Projects

J. D. Hatcher, Maintenance Planning

+G. K. Henry, Electrical Supervisor, Nuclear Plant Engineering

B. E. Hey, Nuclear Licensing Engineer

+R. J. King, Licensing Engineer

D. E. Hill, Construction Engineer, SWEC

• +D. R. Gipson, Assistant Plant Manager, Operations, Chemistry, and

Radiological Waste

• +A. O. Kowalczuk, Assistant Plant Manager, Maintenance & Material

• R. B. Stafford, Director, Operations QA

W. T. Laib, Mechanical Maintenance Foreman

• &I. M. Malik, Supervisory Quality Engineering

• +P. E. Freehill, Superintendent, Startup and Test

• +M. R. Gaupette, Assistant to Project Engineer, Engineering Assurance, SWEC

D. E. Metcalf, QC Planner

• L. Schell, Senior Electrical Engineer

J. E. McGee, QC Inspector

+T. O. Moffatt, Quality Engineer

• +J. H. McQuirter, Nuclear Licensing

• J. J. Zullo, Quality Assurance Manager, Nuclear Parts

• J. D. Mullin, Maintenance Planner

+J. E. McWorter, QA Engineer

K. J. Giadrosich, Senior Quality Assurance Engineering Supervisor

J. Price, Nuclear Licensing

• +H. F. Roark, Electrical Maintenance Supervisor

E. M. Cargill, Health Physics Supervisor

• D. G. Seymour, Compliance Analysis

C. L. Fantacci, Radiation Protection Supervisor

E. P. Shankla, Shift Supervisor

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A. J. Stepanavich, Quality Control (QC) Planner

D. E. Zemel, Maintenance Engineer

R. F. Mendenhall, Electrical Maintenance Foreman

S. D. Justice, Electrical Maintenance Foreman

• W. H. Benkept, Lead Quality Engineer

R. G. West, I&C Supervisor

• C. R. Maxson, Compliance Analyst

• T. Murphy, Planning

F. J. Allison, I&C Foreman

• C. W. Walling, Quality Assurance (QA)

+A. Soni, Nuclear Power Engineering

+P. F. Gillespie, Senior Compliance Engineer

+R. R. Smith, Licensing Engineer

H. J. Huff, Management Systems

• +A. E. Bailey, Operations QC Supervisor

J. A. Taylor, Material Supervisor

R. E. Forster, Mechanical Maintenance Foreman

+H. E. Kook, Nuclear Power Engineering, Electrical

B. E. Bickel, I&C Foreman

D. Reynolds, Supervisor, Document Control

S. Marino, Training

The NRC inspector also interviewed additional licensee and contractor

personnel during the inspection.

• Denotes those attending the exit interview on February 7,1986.

+ Denotes those attending the exit interview on March 7, 1986.

The senior resident and resident inspectors attended both exit interviews.

2. General Maintenance Program

The NRC inspector performed a review of the River Bend Station maintenance

program, including selected administrative and maintenance procedures.

a. Organization and Administration

The assistant plant manager, maintenance and material, reports

directly to the plant manager. He is in charge of the maintenance

engineer, the supervisor of purchasing and material, and the general

maintenance supervisor.

The general maintenance supervisor manages maintenance discipline

supervisors in the fields of mechanical, building and grounds,

electrical, and instruments and controls (I&C). Each discipline

supervisor has foremen who supervise the individual craftsmen and

planners for detailed Maintenance Work Requests (MWR).

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The total number of supervisory levels, including foreman to

4 assistant plant manager, is four. Foremen supervise five to ten

craftsmen.. Higher level maintenance management supervise from two to

six at th(. next lower level.

Maintenance problems and technical issues are resolved-by various

conmittees. These include the Facility Review Committee, the

Technical Staff Reliability Program, the Nuclear Safety Board, and

the Independent Safety Engineering Group. These are supplemented by

task forces working on specific maintenance problems. At the time of

the inspection, approximately 20 task forces were active.

l In addition, River . Bend management supports staff participation in

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nation-wide maintenance-related groups, such as INPO Accreditation ,

J teams fcr maintenance training, the Nuclear Utilities Management and

Human Resources Cccinittee (NUMARC), the Nuclear Plant Reliability

Data System (NPRDS), and the Pooled Inventory Management

System (PIMS).

Some overlapping functions exist in areas such as vibration analysis,

equipment qualification maintenance, and routine preventive

maintenance.

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Planned outages are coordinated by the Outage Management Group, whose

superintendent reports to the plant manager. Individual task

planning is done by maintenance planners,

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b. Policies and Procedures

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l The River Bend Station has procedures covering maintenance

i activities, both preventive and corrective. Inservice inspection,

l equipment qualification, surveillance testing, and maintenance

testing are included in the system,

j Corrective maintenance, preventive maintenance, and predictive

l maintenance programs are defined and controlled by administrative

i procedures (ADM). No goals or objectives for these programs had been

published.

River Bend had operated only 5 months, at limited power, so feedback

from operating experience was not available in many instances.

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River Bend has a system for emergency maintenance (prompt maintenance

MWR). The shift supervisor uses this system as a method of

processing maintenance requests which require solution without

l waiting for day-time processing and planning steps.

Approximately 20 percent of the River Bend surveillance testing is

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not required by regulations or ASME code requirements. The results

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of surveillance testing are used for equipment reliability analysis,

predictive maintenance, planning preventive maintenance, and planning

, corrective maintenance.

In the current fiscal year, approximately 75 percent of maintenance

i is budgeted for corrective maintenance with the balance for

preventive maintenance. Since the plant has been performing low'

power testing since criticality 5 months ago, actual figures are not

known, but most expenditures have been for corrective maintenance,

j The plant staff designs and installs all major modifications.

]- c. Administrative Control

i Thelicenseeusesthecomputer-basedPlantMaintenanceSystem(PMS)

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to determine the status of outstanding work orders and for

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maintenance planning. It is the only system used for maintenance

j tracking'during either normal operations or outages.

} The outage supervisor, in the Engineering Services organization,

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plans all scheduled outages. For normal operations, each discipline

supervisor has his own planning organization. In either case,

detailed job planning is performed by planning and scheduling

j specialists who work for the discipline supervisors.

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The maintenance management periodically uses a computer program to

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calculate performance indicators for each foreman. Thus, comparative

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data for each foreman are continuously evaluated. Maintenance

i management is aware of the NUMARC maintenance performance indicators,

and intends to monitor these. Since plant operating experience is

limited, the most reliable indicators of maintenance effectiveness

are not yet established. '

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As a result of the Davis-Besse event, design calculations for valve

operators have been reviewed, and all valves have been checked for

proper settings.

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l Operating personnel were made aware of the potential problem, and all

operational problems at River Bend are carefully studied to assure no

! generic problems exist.

! d. Communications and Interactions With Other Departments

! Communication and interactions between Maintenance and the other

j departments are described below.

l (1) Quality Assurance and Quality Control (QA/QC)

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Specific lines of communication between QA/QC and Maintenance

are defined in QC's administrative procedures and maintenance

procedures, Quality Assurance and Quality Control report to the

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same manager. QC reviews all safety-related and most

nonsafety-related MWRs and adds hold points as required. The

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hold points are identified on the maintenance procedures during

review of the maintenance work packages. Approximately 85

percent of QC inspector-hours are spent on safety-related

equipment; the inspector to maintenance mechanic ratio is about

1:2.

The average experience of QC personnel is 9.5 years, with most

having prior nuclear maintenance experience. The operations QC

supervisor has 13. years nuclear QC experience, 4 years of which

have been at River Bend. Quality Assurance Engineering (QAE)

has an audit group with five full-time auditors.

(2) Plant Engineering

The specific lines of communication between technical services

and maintenance are defined in administrative procedures. The

technical service group reports to the assistant plant manager

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of technical services and is an onsite organization. It

participates actively in INP0 and other NPRDS programs.

(3) Health Physics

Specific lines of communication between health physics (HP) and

4 maintenance are defined in administrative procedures. All MWRs

requiring access to radiologically controlled areas require a

Radiation Work Permit, which specifies the controls required.

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Work in radiation levels over 2.5 R/hr or doses expected to

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exceed 10 man-rem require ALARA review. Briefings of the

mechanics, area maps, and continuous HP monitoring in high

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radiation areas are used to limit radiation doses.

Radiation exposure is tracked in the six basic categories

- required by NRC, as well as by job. Total radiation dose per

year for the site is not presently used as a maintenance

performance indicator.

I (4) Maintenance Staff

I Mechanical, electrical, and instrument staff personnel

experience varies considerably, from 9 to 12 years for

instrument and mechanical to 1.5 years for electrical.

' Supervisors' experience in all crafts runs from 10 to 25 years.

4 Coverage of work by supervisors above foreman varies from

10 percent in I&C to 75 percent in electrical. All maintenance

staff people interviewed felt they received adequate support

from engineering. The maintenance people estimated they spent

60-80 percent of the day in useful maintenance work if briefings

and document review are counted as useful work. QC monitors

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most safety-related work by using hold points. Sixty to eighty

percent of safety-related work is monitored by QC. I&C

personnel performing troubleshooting or preventive maintenance

are not monitored by QC.

e. Facilities and Equipment

The River Bend maintenance facilities and equipment are described

below.

The craft workshops were sized using experience at other plants as

much as possible, and the size of the various shops appears adequate

from the standpoint of work space to avoid any adverse effects on the

quality or efficiency of maintenance work done at the plant.

ALARA considerations permitting, most mechanical work is performed at

the equipment location. The electrical and I&C crafts perform

maintenance in the shop area or in the plant. Electrical work is

occasionally limited by the need for an area equipped with heavy

hoisting equipment.

I&C has 60 work spaces in 2 areas, and Electrical has 20 work spaces.

The mechanics work spaces are not defined. Maintenance has not been

affected by lack of work space.

Two tool cribs are available; one for clean and the other for

contaminated work. A study of tool crib size and location has been

performed by outside consultants, but no modifications are planned

until more operating experience is gained. All tools are stored in

the tool cribs except the individual mechanic's tools and the machine

shop's tools. Availability of tools or tool crib space has not

affected maintenance.

Contaminated tools may be decontaminated or restricted to the

contaminated tool crib. Calibration of contaminated tools such as

torque wrenches is usually accomplished with special standards.

The size and permanent location of the contaminated storage area will

not be determined until more operating experience is gained.

The warehouse size is adequate, and all items are stored there, with

the exception of extremely bulky materials and some special items.

The distance of the warehouse from work areas apparently causes some

inconvenience.

f. Licensee Procedures Reviewed

The following licensee procedures were reviewed:

(1) ADM-0003 " Development, Control and Use of Procedures"

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(2) ADM-0006 " Control of Plant Records"

(3) ADM-0015 Revision 7, " Surveillance Test Program"

(4) ADM-0018 " Plant Housekeeping and Cleanliness Cor. trol"

(5) ADM-0019 " Initiation and Processing Condition Reports"

(6) ADM-0023 Revision 5, " Conduct of Maintenance," dated

November 18, 1985

(7) ADM-0027 Revision 3, " Protective Tagging," dated September 14,

1985

(8) ADM-0028 Revision 4, " Maintenance Work Request," dated

July 25, 1985

(9) ADM-0030 Revision 3, " Reporting and Processing ,

Nonconformances"

(10) ADM-0048 Revision 0, " Performance Monitoring and Trend

Analysis," dated October 16, 1985

(11) NUPE-AA-41 Revision 1, " Evaluation of Interchangeability of

Spare Parts"

(12) NUPE-AA-42 Revision 1, " Evaluation and Justification of

Commercial Grade Spare Parts"

(13) NUPE-AA-65 Revision 0, Vendor Manual Applicability Review

(14) CMP-1253 Revision 3, "Limitorque Motor Operated Valves," dated

February 3,1986

(15) CMP-9136 Revision 1, Velan Motor Operated Gate Valve . . .

Disassembly, Inspection, Rework, and Assembly

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(16) FPP-0060 " Hot Work Permit"

(17) GMP-0015 Revision 2, " Lubrication Procedure," dated

December 5, 1985

(18) GMP-0018 " General Torquing Guide"

(19) GMP-0042 " Control Circuit Testing"

(20) GMP-0068 " Disassembled Components Identification and Control"

(21) MCP-4000 Revision 2, " Device Calibration," dated December 17,

1985

(22) MCP-4001 Revision 0, " Loop Calibration," dated May 29, 1984

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(23) MCP-4068 Revision 2, " Calibration of Rosemount Model 1153

Transmitter," dated October 16, 1985

(24) MHP-0012 Revision 0, " Return of Material to the Storeroom,"

dated December 24, 1985

(25) MSP-0002 " Corrective Maintenance Program"

(26) MSP-0003 Revisions 3 and 4, " Preventative Maintenance Program"

(27) MSP-0005 "Special Maintenance Process"

(28) MSP-0009 Revision 5, " Qualification of Maintenance Personnel,"

dated November 6, 1985

(29) MSP-0011 " Certification and Training of Personnel for Special

Processes"

(30) MSP-0014 " Housekeeping"

(31) MSP-0021 Revision 2, " Equipment Removal Tagging," dated

January 13, 1986

(32) NPE-3-007 " Instructions and Requirements of Use of the

River Bend Q-List"

(33) PMP-1205 Revision 3, " Motor Operated Valve Routine

Maintenance," dated November 26, 1985

(34) QAl-2.1 Revision 2, Audit Performance and Reporting

(35) QAD-9 " Control of Special Processes"

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(36) QAP-1.3 Revision 4, " Quality Assurance Indoctrination and

Training Program Procedure," dated May 7, 1985

(37) QAP-1.5 Revision 4, " Certification of Nondestructive

Examination Personnel," dated August 23, 1985

(38) QCI-3.2 Revision 2, " Inspection of Maintenance Activities

Associated With '4aintenance Work Requests," dated

January 14, 1986

(39) STP-000-3606 Revision 0, "Section XI Safety and Relief Valve

Testing," dated June 25, 1985

(40) STP-209-0601 Revision 2, " Return of Material to the

Storeroom," dated December 24, 1985

(41) STP-305-1100 " Battery Weekly Surveillance Test for Battery

1ENB* BAT 01A"

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(42) STP-309-0201 " Diesel Generator . Division 1 Operability Test"

(43) Gulf State Utilities Quality Assurance Manual

(44) Quality Assurance Lepartment frahing, Qualtficatica and

Certification Maapa'i

g. Failure to Have Procedures for Activities Relating to Ma!ntenance

The NRC inspectors noted several areas of apparent procedural

inadequacies relating to the maintenance area as follows:

(1) Incorporation of Vendor Technical Information in Maintenanc.' .

Procedures

At the time of this inspection the licensee had not incorporatid

in plant maintenance procedures certain venoor technical

information available on site. This concern was first '

identified by the licensee in Quality Assurance Fi, ding

Report (QAFR) No. 0-84-10-35E, dated October 1, 1984, and

QAFR E-84-11-280, dated October 31, 1984. Subsequer,t audits ,

such as GSUS/EQAL-85/08 and 85/10, and QAFR 0-86-01-14-D have

identified that this problem had not teen resolved. The NRC

inspector found vendor specified maintenance for the RCIC

turbine (see paragraph 6.e), safety-related Rosemount -

transmitters, and containment cooling fan motors had not been

incorporated in licensee maintenance procedures.

The licensee hau no procedure that required review of vendor

equipment technical information relating to maintenance, and its

adaption and incorporation into site maintenance procedures,

prior to performance of maintenance on the equipment.

(2) Configuration Control for Maintenance Procedures Containing

Vendor Technical Information (VII) ,

The license did not identify in site maintenance procedures the

revision of VTI incorporated; nor did they have a system that

could identify the applicable revisions of VTI that were

incorporated. When new revisions of VTI were received, they

were added to a master computer list, but were not highligSted '

or otherwise identified. No licensee procedure required review

and incorporation in maintenance procedures of revisions to VTI.

(3) Periodicity Requirements for Maintenance of Qualification of ,

Equipment Qualification ,

Licensee maintenance procedures began periodicity at fuel load. ,

As discussed in paragraph 5, the licensee allowed a +25 percent

time interval on periodicity. Some manufacturers specify

periodicity to begin at the date of manufacture. Ex'amples are

capacitors and Agastat relays. Equipment Qualification (EQ)

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periodicity, and some other equipment periodicities, allow no

plus tolerance. The licensee's generic +25 percent tolerance

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had been established without apparent consideration or review of

j exceptions.

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l (4) Root Cause Analysis

The licensee is comitted to Regulatory Guide 1.33, ANSI

Standard N18.7-1986. N18.7-1976, Section 5.2.7.1, states that

the causes of malfunctions shall be promptly determined,

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evaluated, and recorded. The licensee could not identify a

procedure to assure that this requirement is fulfilled.

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! (5) Conclusion

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River Bend Station Technical Specification 6.8.1.a requires that

written procedures shall be established, implemented, and

maintained covering the applicable procedures recommended in

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Appendix A of Regulatory Guide (RG) 1.33, Revision 2,

February 1978. RG 1.33, Revision 2. Section 9 requires

procedures for performing maintenance. Furthermore, 10 CFR 50,

j Appendix B, Criterion V requires procedures for activities

i affecting quality.

l The failure to have administrative procedures requiring the

t incorporation of VTI in maintenance procedures and requiring

revision control and use of the latest VTI, the failure to have

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procedures properly controlling the periodicity of preventive

! maintenance, and the failure to have procedures implementing

3 root cause analysis, as set forth in ANSI 18.7, Section 5.2.7.1,

is an apparent violation of River Bend Technical Specifica-

l tion 6.8.1 and 10 CFR 50, Appendix B, Criterion V. (458/8606-01)

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h. Sumary

The River Bend plant had been operating at limited power for

approximately 5 months at the time of the inspection. As a re:, ult,

there has been limited maintenance program feedback, such as location

l of hot laydown areas, tool crib design and location, full

I implementation of the preventive maintenance program, inservice [

l inspection programs, predictive maintenance programs, and maintenance

j of equipment qualifications. River Bend had not completed actions

i related to Generic Letter 83-28, the Salem ATWS event. i

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i All personnel who were contacted demonstrated professional knowledge l

of the plant and their responsibilities, and enthusiasm and pride  !

concerning plant activities. The licensee demonstrated a positive 1

attitude toward maintenance. An example noted by the inspector was

! the aggressive manner in which they accomplished a detailed

l inspection program of Limitorque actuators after one had failed. I

Other examples included their program for refurbishment of AKR 30 and

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50 circuit breakers, and their performance of a detailed ' internal QA

audit to ensure that their maintenance program was performing as

intended and that document storage was adequate.

3. MechanicalMaintenanceProgrim_

-l In the mechanical maintenance area, the NRC inspector performed an

inspection of maintenance history, work item tracking, and maintenance

work requests.

The following Mechanical Maintenance Organization personnel were

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interviewed to determine their areas of functional responsibility and

their qualifications: maintenance supervisor, mechanical foreman,

inspector, parts specialists, and welding er.gineer. The QA manager was

also interviewed.

The following Maintenance Work Requests (MWR) were reviewed:

MWR 12570, " Service water to RHR testable check valve" a request to

correct a nonfunctioning valve open indicator No. 1E12*A0V F098; this

MWR superseded MWR No. 007101,

MWR No.11587, "RWCU A Pump Suction Valve" a request to repair a

packing leak on valve No. 1G33*MOV F001, and

MWR No.14750, " Injection Valves on RHR and LPCS Systems" a request

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to inspect the worm gears on four valves; IE12*MOV F042A, B, C, and

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Each MWR was checked for authorizing sigcatdres, func'tional testing, spare

parts control, adequacy of inspection. mechanical qualification, adequacy

of descriptive portions detailirg.thecnaintenance performed and functional

testing and restoration. The MWRs were reviewed to determine if the

requirements of Administrative Procedure ADM-0023. Revision 5 " Conduct of

Maintenance," ADM-0027, Revision 3 Protective Tagging, and ADM-0028

Revision 4 " Maintenance Work Requests," had been incorporated. No

violations or deviations were identified.

4. Instrumentation Maintenance Program, Observation of Work, and Review of

Quality Records

The NRC inspector performed an in-depth review of the maintenance program

in the instrument and control areas. Maintenance history, calibration

reca ds, qualification records, procedures, work item tracking forms, and

maintenance work request forms were obtained and reviewed. The following ,

I&C Maintenance Organization personnel were interviewed to determine their '

area of functior.sl responsibility, and qualifications: I&C Supervisor, I&C

Foreman, and technicians. s

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Fifteen completed maintenance packages were reviewed. The following six

were considered to be significant enough to warrant further review:

MWR No. 13234, HPC Flow Transmitter M41ntenance.

MWR No. 007223, RHR-A Room Level Indicator,

MWR No. 10282 APRM-B Out of Tolerance (the MWR requirements

had been shifted to MWR No. 13837),

MWR No. 13837, APRM A & H.

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MWR No. 13456, RWCU Demineralizer Room 1, and

MWR No. 19173, APRM G.

During the review of these packages, a concern was identified. MWR

No. 13234 requires the performance of maintenance of the HPC flow

transmitter. The work requirements referenced a nonconformance

report (NR) No. 85NR0391-00. A copy of the NR was attached to the MWR.

When the NR was reviewed by the NRC inspector, it was found to identify

work that was perfonned approximately 2 months earlier. It was not clear

how this NR was applicable, what work was done, and what sequence of :teps

was used to perform the work. The licensee reviewed this item and

provided an explanation during the second week of the inspection. The

explanation adequately addressed the concern.

Two maintenance-related activities were witnessed to verify compliance

with the appropriate maintenance proccdures. These activities were the

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performance of two surveillance test procedures (STP-505-4507, RPS-APRM

Weekly CHFUNCT, Weekly CHCAL (C51-APRM G) and STP-207-4247 Reactor Water

Cleanup System Isolation Equipment Area Differential Temperature High

Monthly CHFUNCT, 18-Month CHCAL, 18-Month LSFT (E31-N6198)). One concern

was identified during the performance of STP-505-4507. This test required

jumpers to be installed in a confined space. The terminals on which they

are installed are in close proximity to other terminals. When the jumpers

) were installed, the technician shorted the terminals together resulting in

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arcing and a blown fuse. When questioned, the technicians indicated that

this condition had been experienced be# ore. They also identified a

Modification Request that had been initiated which would install a patch

panel to eliminate the requirement for a jumper to be installed in the

confined space. This proposed modification satisfies the concern.

, Maintenance of the qualification of safety-related Rosemount 1153

l transmitters was reviewed. It was determined that if Maintenance

Procedure MCP-4068 (Calibration of Rosemount Model 1153 trcnsmitters,

i Revisions 0,1, and 2) were ased, equipment qualification could be voided

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because of omitted maintenance qualification requirements. On

February 12, 1986, after this was brought to the attention of the

licensee, a temporary change notice was issued to correct this procedure.

In addition, records for corrective maintenance and preventative

maintenance were reviewed by the NRC inspector to determine if

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qualification had been compromised for any safety-related instruments

because of the omitted requirements. No preventive maintenance had been

perfonned using the improper requirements. Corrective maintenance had

been performed, but this did not require performance of maintenance that

would have voided qualification.

Records of performance of 15 Surveillance Test Procedures (STPs) were

reviewed to determine if o-rings had been replaced, lubricated, and

instrument covers torqued on safety-related Model 1153 Rosemount

l transmitters as required to maintain qualification. Twenty-two functional

checks had been performed on Rosemount transmitters. The functional

checks did not require removal of the protective covers and therefore, did

not require o-ring replacement. Six STPs required instrument

recalibration. In those six cases, the o-rings were properly replaced and

the protective cover properly installed and torqued.

5. Electrical Maintenance Program Observation of Work and Review of Quality

Records

The NRC inspector performed a review of the licensee's electrical

maintenance program and applicable River Bend administrative and

maintenance procedures. Maintenance history, work item tracking forms,

maintenance work requests, qualification records, document control

procedures, and replacement part records were reviewed. The following

Electrical Maintenance Organization personnel were interviewed to

determine their area of functional responsibility and qualifications:

electrical supervisor, electrical foremen, and electricians.

Procedures and documentation associated with four completed maintenance

activities were reviewed. The completed activities were:

MWR No. 24114. HPCS CST Return Valve Maintenance (which had been

shifted to MWR No. 6569),

MWR No. 6569, Limitorque SMB-4 Motor Operator MOVs Maintenance (the

HPCS CST Return Valve M0VF011 part only),

MWR No. 2954, IEE*MOVF023 Maintenance, ar.d

MWR No. 17338, Division 1 Standby Diesel Generator Maintenance. I

No violations or deviations were identified during the review of these

packages. '

Work associated with two MWRs was reviewed to insure that licensee

personnel performing work followed the appropriate maintenance work

requests (MWRs). The MWRs were:

MWR No. 006573, Various Limitorque Actuators Torquing (1-SWP*M0V-558 i

only),

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MWR No. 19120. Feedwater Pump IC Maintenance (only until~ bearing was

removed).

Two problems were identified during the performance of MWR No. 006573.

MWR No. 006573 was issued to cover the performance of yoke bolt torquing

on several types of Limitorque actuators. Inspection hold points,

included on the work package during the review process, were specified for

the different types of actuators involved. Since the work was done on

different actuators, not all hold points were applicable for each

actuator. When the work was done, the nonapplicable hold points were left

blank. By leaving these points blank, the licensee failed to follow

Section 3.3.3 of QC Procedure QCI-3.2, Revision 2. The requirement by

their procedure was to get a QCS to waive the hold point. This was not

done. The second concern identifiea was that a signed-off copy of MWR

No. 006573 was not used in torquing on valve ISWP*M0V-55B; a copy of the

original was used. It was determined that the appropriate approvals had

been obtained and were in the master MWR documentation package in the

electrical shop. The work package made for valve maintenance was prepared

before sign-offs had been obtained. The licensee explained that this MWR

had been issued to cover the same work on a large number of valves and

that a separate package had been made for each valve by copying the

original. In generating work packages this way and not having a

signed-off copy of the MWR at the work site, the licensee failed to follow

step 5.9.6 of their Administrative Procedure ADM-0028, Revision 4. The

licensee revised Procedure ADM-0028 to address the requirement for having

an original signed-off MWR copy at the job site for review. The revised

procedure deleted the requirement for having an original photo copy. A

revision to Quality Procedure, QCI-3.2, was submitted to more clearly

delineate the limitations of a QC inspector. The change also added words

that nonapplicable steps would be marked as not applicable, initialed, and

dated, rather than being left blank. These failures to follow procedures

constitute an apparent violation; however, immediate and satisfactory

corrective action was taken to prevent recurrence, and the licensee is

not required to respond.

l Another concern, which appears generic, was identified during the

l inspection. EQ preventive maintenance is identified on the PM schedule

with all other PM. It is not identified as EQ. By the licensee's

procedures, PM periodicity can exceed the specified interval by 25 percent

of the periodicity time span. A 10-year-interval could be automatically

l extended to 121 years before the maintenance is considered to be late. In

,

some cases the 25 percent late criteria could cause qualified equipment to

'

lose its qualification.

l The licensee responded by changing their EQ maintenance identification so

that it is uniquely identified. The EQ maintenance timing requirements

were also changed so that maintenance will be performed before

qualification is lost.

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6. QA Program (Maintenance)

a. General

The NRC inspector reviewed the licensee's QA program implementation

for maintenance activities in conformance with the Technical

Specifications, regulatory requirements and committed industry

standards. These requirements were found in the QA manual, QA

directives, administrative, maintenance (electrical, mechanical, and

instrument and control), operations and engineering procedures.

Personnel from each organization were interviewed concerning

implementing these requirements. Additionally, MWR packages were

reviewed to determine implementation and compliance with procedures.

Some procedure requirements appear subject to more than one

interpretation. Specific differences in interpretation of procedure

requirements are:

o Review and determination of malfunction and cause of failures

o Trending analysis of failures

o Identifying of safety /nonsafety jobs in the MWR by the shift

i supervisor and the maintenance planner.

b. Trend Analysis

There was little evidence that trend analysis is performed on the

causes of safety-related equipment malfunctions or failures. This

will be reviewed further during a subsequent inspection.

1

c. Maintenance Document Closure

l The NRC inspector did not find a procedure that identified the

documents to be included in the ::ompleted (closed) MWR packages.

When reviewing completed MWRs, it could not be determined if minimum

required documents were included in the stored document files.

10 CFR 50, Appendix B, requires sufficient records be maintained to

document activities affecting quality.

During the second week of the inspection, the licenses submitted a

revised document control procedure (ADM-0028). The administrative

procedure was revised to identify the documents necessary for storage

as part of the MWR package. This appears to adequately address the

Concern.

d. Material Control and Traceability

An observation was made concerning control of installed material in

safety-related systems.

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MWR No. 003773 required two spiral wound metal-asbestos gaskets to be

installed in orifice flanges. These items were withdrawn on a stores

requisition (SR) 28701, dated November 26, 1985, and its yellow copy

added to the MWR package. The MWR number was recorded on SR28701,

but the stores requisition number was not recorded on the MWR.

Personnel interviewed stated that the yellow stores requisition copy

may not be included in the MWR permanent files. When the gasket was

installed, material identification numbers were not recorded in the

MWR. Personnel who were interviewed informed the NRC inspector that,

to determine the identity of installed parts, one must go to the

warehouse and have the original stores requisition retrieved. This

method does not assure parts withdrawn are the parts installed.

Three MWRs (002526, 002527, and 002675), requiring fabrication and

installation of parts in safety-related systems, were randomly

selected from document storage files. The licensee was requested to

provide material traceability for these parts. Of the three MWRs,

the licensee was able to provide evidence of acceptability for one

(002675).

Material acceptability was not provided for the other two. This item

is considered unresolved pending further review by the NRC inspector

to determine whether material acceptability has been established

(458/8606-02).

e. Incorporation of VTI

The RCIC turbine manual preventive maintenance (PM) requirements l

were compared to PM included in licensee PM procedures. Three

discrepancies were identified. The manual requires: i

(1) yearly overspeed testing, for which no licensee procedure was

identified,

(2) linkages to be cleaned, lubricated, and inspected quarterly,

but the licensee is doing this yearly; and

(3) weekly and monthly PMs, for which no licensee procedure was 1

f

identified,

l

VTI is also discussed in paragraph 2.g.

f. FSAR Table 3.9B-3a Was Not Current l

One of the valves (E22*MOV F001) which was selected for qualification

document review, from the active equipment list in the FSAR, had to

be dropped from the inspection as the valve was no longer considered

to belong on the active list. The licensee stated that the valve had

been dropped from the list greater than 1 year earlier due to a

reevaluation of requirements. This is an open item (8606-03) pending

further review by the NRC inspector during a subsequent inspection.

l

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7. Vendor Manuals

Vendor technical manuals were compared against an interoffice memorandum

dated June 6, 1978, from J. A. Kirkebo to all responsible, principal, and

lead engineers. The subject memorandum identified information that should

be contained in all vendor manuals. During the comparison, nine manuals

were reviewed and five were found to have anomolies. This will remain an

open item (8606-04) pending review by the NRC inspector during a

subsequent inspection.

8. Exit Interviews

The inspectors met with the licensee representatives (denoted in

paragraph 1) on February 7 and March 7, 1986, and summarized the scope and

findings of inspection activities. The senior resident inspector attended

these meetings.

l

l

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