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{{Adams | |||
| number = ML20207G251 | |||
| issue date = 06/17/1986 | |||
| title = 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 | |||
| author name = Boardman J, Hunnicutt D | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000458 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-458-86-06, 50-458-86-6, NUDOCS 8607220742 | |||
| package number = ML20207G225 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 18 | |||
}} | |||
See also: [[see also::IR 05000458/1986006]] | |||
=Text= | |||
{{#Wiki_filter:- | |||
. | |||
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 | |||
G | |||
e | |||
* | |||
. | |||
2 | |||
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 | |||
_ _ _ - _ _ _ _ _ | |||
* | |||
. | |||
3 | |||
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). | |||
.. | |||
.. ._. _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ I | |||
- . . - .. -- . . . - -- | |||
: | |||
' | |||
i. | |||
i~ 4 | |||
) | |||
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 | |||
- | |||
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. | |||
' | |||
Planned outages are coordinated by the Outage Management Group, whose | |||
superintendent reports to the plant manager. Individual task | |||
planning is done by maintenance planners, | |||
t | |||
b. Policies and Procedures | |||
! | |||
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. | |||
I | |||
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 | |||
' | |||
not required by regulations or ASME code requirements. The results | |||
! | |||
, | |||
______ _____ | |||
- . . . _ . _ _ _ _. ._ _ __ _ __ | |||
1 | |||
: | |||
* | |||
. | |||
f | |||
5 | |||
. | |||
' | |||
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) | |||
' | |||
to determine the status of outstanding work orders and for | |||
, | |||
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, | |||
' | |||
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. | |||
I | |||
: The maintenance management periodically uses a computer program to | |||
, | |||
calculate performance indicators for each foreman. Thus, comparative | |||
- | |||
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. ' | |||
i | |||
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. | |||
i | |||
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) | |||
i' | |||
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 | |||
~ - _ _ -, _ , - _ - _ _ . _ , _ . _ _ _ _ _ . _ _ _. _._ _ .__ _ _-_ _ | |||
- _ - .. _ --. - , - - | |||
1 | |||
.- | |||
, | |||
6 | |||
s | |||
F | |||
same manager. QC reviews all safety-related and most | |||
nonsafety-related MWRs and adds hold points as required. The | |||
1 | |||
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 | |||
i | |||
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. | |||
l | |||
Work in radiation levels over 2.5 R/hr or doses expected to | |||
' | |||
exceed 10 man-rem require ALARA review. Briefings of the | |||
mechanics, area maps, and continuous HP monitoring in high | |||
i | |||
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 | |||
, | |||
--- .-r---.., ,_.,_.n . | |||
_.n.-- .--------n.-----~. - - - - . . - - . . - . , ,----..-..--,n , , - , , - - , - - - - - - , , - , | |||
_ _ _ ________ -___ _ | |||
.. | |||
- | |||
. | |||
7 ; | |||
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" | |||
. | |||
8 | |||
(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 | |||
' | |||
(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 | |||
__ _ . | |||
* | |||
. | |||
9 | |||
(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" | |||
' | |||
(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" | |||
P | |||
- | |||
. | |||
10 | |||
(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) | |||
, | |||
t | |||
- . - . . . | |||
., . - - - . . - . . - , . _ , . . - - . . - , .- - -. ;- - --,-- | |||
_ _ _ _ .. _ _ _ _ _ _ . _ _ _ _ . . _. . _ . ._ . _ - _ _ _ _ | |||
- | |||
.. | |||
l 11 | |||
j - | |||
: periodicity, and some other equipment periodicities, allow no | |||
; plus tolerance. The licensee's generic +25 percent tolerance | |||
, | |||
had been established without apparent consideration or review of | |||
j exceptions. | |||
t | |||
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, | |||
- | |||
evaluated, and recorded. The licensee could not identify a | |||
procedure to assure that this requirement is fulfilled. | |||
i | |||
! (5) Conclusion | |||
i | |||
' | |||
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 | |||
! | |||
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 | |||
! | |||
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) | |||
! | |||
t | |||
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 | |||
! 'i | |||
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 | |||
I | |||
i | |||
: | |||
' _ _ _ _ _ , _ _ _ , _ _ . _ . _ _ _ . | |||
- - -- | |||
.- | |||
' ' | |||
.. | |||
t | |||
. | |||
I | |||
- | |||
l 12 | |||
4 | |||
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 | |||
! | |||
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 | |||
l | |||
to inspect the worm gears on four valves; IE12*MOV F042A, B, C, and | |||
l D. | |||
l | |||
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 | |||
. | |||
. | |||
. . _ _ _ . - . - ,_ - _ | |||
. _ _ _ . . - . . .-_- -- _ .. .. .. _-. _ _ - - - - - . - - - . _ | |||
* | |||
.. | |||
. 13 | |||
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. | |||
, | |||
* | |||
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 | |||
, | |||
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 | |||
' | |||
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 | |||
' | |||
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 | |||
___ _ | |||
* | |||
.. | |||
, | |||
14 | |||
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), | |||
._ - -. - - .. _ - . . - - - _ - - | |||
* | |||
.. | |||
. 15 | |||
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. | |||
- | |||
* | |||
.. | |||
* | |||
16 | |||
' | |||
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. | |||
* | |||
.. | |||
- 17 | |||
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 | |||
.-- - | |||
- | |||
.. | |||
18 | |||
. | |||
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 | |||
. | |||
}} |
Latest revision as of 16:56, 19 December 2021
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: |
References | |
50-458-86-06, 50-458-86-6, NUDOCS 8607220742 | |
Download: ML20207G251 (18) | |
See also: IR 05000458/1986006
Text
-
.
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
G
e
.
2
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
_ _ _ - _ _ _ _ _
.
3
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).
..
.. ._. _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ I
- . . - .. -- . . . - --
'
i.
i~ 4
)
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
-
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.
'
Planned outages are coordinated by the Outage Management Group, whose
superintendent reports to the plant manager. Individual task
planning is done by maintenance planners,
t
b. Policies and Procedures
!
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.
I
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
'
not required by regulations or ASME code requirements. The results
!
,
______ _____
- . . . _ . _ _ _ _. ._ _ __ _ __
1
.
f
5
.
'
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)
'
to determine the status of outstanding work orders and for
,
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,
'
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.
I
- The maintenance management periodically uses a computer program to
,
calculate performance indicators for each foreman. Thus, comparative
-
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. '
i
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.
i
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)
i'
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
~ - _ _ -, _ , - _ - _ _ . _ , _ . _ _ _ _ _ . _ _ _. _._ _ .__ _ _-_ _
- _ - .. _ --. - , - -
1
.-
,
6
s
F
same manager. QC reviews all safety-related and most
nonsafety-related MWRs and adds hold points as required. The
1
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
i
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.
l
Work in radiation levels over 2.5 R/hr or doses expected to
'
exceed 10 man-rem require ALARA review. Briefings of the
mechanics, area maps, and continuous HP monitoring in high
i
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
,
--- .-r---.., ,_.,_.n .
_.n.-- .--------n.-----~. - - - - . . - - . . - . , ,----..-..--,n , , - , , - - , - - - - - - , , - ,
_ _ _ ________ -___ _
..
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7 ;
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"
.
8
(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
'
(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
__ _ .
.
9
(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"
'
(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"
P
-
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10
(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)
,
t
- . - . . .
., . - - - . . - . . - , . _ , . . - - . . - , .- - -. ;- - --,--
_ _ _ _ .. _ _ _ _ _ _ . _ _ _ _ . . _. . _ . ._ . _ - _ _ _ _
-
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j -
- periodicity, and some other equipment periodicities, allow no
- plus tolerance. The licensee's generic +25 percent tolerance
,
had been established without apparent consideration or review of
j exceptions.
t
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,
-
evaluated, and recorded. The licensee could not identify a
procedure to assure that this requirement is fulfilled.
i
! (5) Conclusion
i
'
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
!
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
!
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)
!
t
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
! 'i
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
I
i
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- - --
.-
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4
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
!
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
l
to inspect the worm gears on four valves; IE12*MOV F042A, B, C, and
l D.
l
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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. 13
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.
,
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
,
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
'
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
'
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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,
14
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),
._ - -. - - .. _ - . . - - - _ - -
..
. 15
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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16
'
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.
..
- 17
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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18
.
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
.