IR 05000293/1987036

Insp Rept 50-293/87-36 on 870817-21.Violation Noted.Major Areas Inspected:Maint Program,Including Staffing & Training, Maint Activities,Maint Procedural Controls,Matl Condition Improvement Action Plan & Qa/Qc Interfaces

ML20235L381
Person / Time
Site:	Pilgrim
Issue date:	09/16/1987
From:	Bissett P, Blumberg N, Chaudhary S, Denise Wallace NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235L324	List: IR 05000293/1987036 ML20235L322 ML20235L353
References
50-293-87-36, NUDOCS 8710050447
Download: ML20235L381 (12)

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-36 Docket N License N DPR-35 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth and Chiltonville, Massachusetts Inspection Conducted: August 17-21, 1987 Inspectors: P.Bissett/L(adReactorEngineer,DRS

     / 7   [" M~' [7 date h(khb S. Chaudhary' Fead Reactor Engineer, DRS f- /r- 17 date ff D. T. WallaceVReactor Engineer, DRS M   f' N date Approved by:    -' ^ -
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3. Maintenance Program I 3.1 Scope and Criteria l Several inspections of the maintenance program at the Pilgrim l Nuclear Power Station (PNPS) have been conducted within the past several months. During these inspections, several areas of interest and/or concern were noted (re: NRC Inspections Reports I 86-06, 86-27, 86-43 and 87-12). The majority of effort directed during this inspection was towards assessing the progress made by the licensee within those areas of concern previously identifie Specific areas of maintenance selected for review included the i following:

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Material Condition Improvement Action Plan

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Staffing

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Training and qualification

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Oversight and control of contracted work

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Quality of completed and ongoing maintenance work ;

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Maintenance requests ' _ _ _ _ _ - _ _ _

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. 3 Administrative controls (listed in Attachment 1) relevant to those areas listed above were reviewed to assure that various aspects of the maintenance program were consistent with the following requirement * Pilgrim Station Technical Specifications
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Regulatory Guide 1.33, Quality Assurance Program (Operation)

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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants 3.2 Maintenance Review / Implementation 3.2.1 Material Condition Improvement Action Plan In July, 1987, the licensee initiated the formalization of the Material Condition Improvement Action Plan (MCIAP). The MCIAP was developed, per upper management's request, to improve upon the material condition of plant equipment and to further enhance - the manner in which maintenance activities were conducted at the sit An independent assessment was initially made of present site maintenance practices in order to identify areas in which improvements needed to be made. The areas reviewed included, but were not limited to, maintenance planning, scheduling, work practices, staffing, training and management control. From this assessment evolved the MCIAP, which was made up of numerous

  " restart" and "long term corrective action" item Each identi- .

fied action item is assigned to various management personnel j responsible for monitoring the completion of specified correc- 1 tive actions, f

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A review staff was also established to independently monitor j and verify the satisfactory completion of all MCIAP action i item This group is comprised of five individuals and their i specific responsibilities included (1) monitoring the progress I of actions taken in satisfying MCIAP action items; (2) verifying ) the adequateness of corrective actions either through document ) reviews and/or direct observations; (3) periodically reverifying l items previously closed; and, (4) assessing the effectiveness of j corrective actions take ! l The inspector held discussions with the review staff personne I From these discussions, it was noted that this group is also l responsible for monitoring and verifying actions taken pertain-ing to, not only the MCIAP, but also, the Restart Plan, Restart l Plan Appendix 10 (Restart Regulatory Responses), and the Radio- l logical Action Plan. Of particular interest to the inspector was the status of the MCIAP Restart items, especially since ; I l l

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. 4 there were approximately 90 Restart items and the MCIAP had not been issued until July 28, 1987. The review staff leader stated that for the majority of restart items, corrective action had actually begun in early May 198 A review of the status of MCIAP Restart Actions indicated that, to date, 37 items have been closed by the licensee and another seven were ready for closur The inspector stated that the MCIAP and the progress of Restart Action item closure would be subject to further review during subsequent NRC inspection There were no further question .3 Staffing and Qualification of Maintenance Personnel 3.3.1 Organization and Staffing The inspector examined the current organization of the licensee's maintenance department, and reviewed the associated staffing plan for this organizatio This examination and review was performed to determine the adequacy of the organi-zational structure, staffing plan, and tne training and quali-fication of the assigned personnel to effectively carryout the assignments and the goals of the maintenance department. The inspection consisted of a review of documentation, discussions with cognizant personnel, and a tour of the licensee's training facilitie Based on the above examinations, reviews, and discussions, the inspector determined the following:
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The licensee has established a separate planning and scheduling group within the Maintenance Department to relieve maintenance supervisors from this responsibilit * Separating the planning and scheduling, and routine documentation responsibility from the first line maintenance supervision appears to have increased the effectiveness of technical and supervisory functions of the maintenance staf * The licensee's current staffing plan calls for gradually replacing all contractor personnel in the maintenance department by direct licensee employees as qualified personnel are hired and/or made available from within the BECO employee poo * The current staffing of the maintenance department appears l to be adequate to perform assigned responsibilities.

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. 5 3.3.2 Training and Qualification The inspector toured the licensee's offsite training facilities, held discussions with the training department instructors and management personnel, and randomly reviewed training records of some maintenance personnel to determine the adequacy of training facility, instructional methods and staff, and the documentation of training conducte Based on the above effort, the inspector determined the following:
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The licensee's training facilities in Chiltonville, MA is more than adequate to meet the needs of maintenance staf * Training is conducted by fully qualified and experienced instructors with comprehensive lesson plan * The lesson plans are task oriented to provide primary and/or refresher skills in an area of work activit * The lesson plans are revised or new ones developed as changes in the established tasks or as new tasks are identifie * The training and qualification of personnel are tracked by computer with capability of hard copy retrieva i i

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The licensee is implementing a rotational program in which l all personnel from maintenance department will be assigned i for structured training for one full shif t after every five work shift , I The inspector had no further questions in this are No violations or deviations were identifie .4 Contractor Maintenance Activities ) 3.4.1 Review / Implementation The inspector conducted discussions with contractor and Boston ; Edison Company, (BECO) personnel and reviewed maintenance i activities in order to determine the conduct of contracted maintenance activitie The inspector's review consisted of the following elements:

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Review of Administrative Procedure 1.3.20, " Control and Utilization of Contractor Personnel and Contractor ! Supplied Material," Revision l i I _ _ _ _ _ _ _ - - ._

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Verification that contractor maintenance activities are controlled through the use of properly authorized, station approved maintenance procedure l

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Verification that contractor maintenance personnel report ' to, or are directly supervised by BECO personne * Verification that measuring and test equipment utilized by contractor personnel is properly controlled and calibrated in accordance with Pilgrim station administrative control * Verification that adequate Quality Control (QC) coverage and oversight of contracted maintenance activities is establishe .4.2 Findings During the inspector's observation of contracted maintenance performed for the Analog Trip System Loop Test of Rack C2206 Transmitters under the control of maintenance request (MR) 86-45-20, the following attributes were noted:

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Pilgrim station maintenance personnel exercised adequate oversight of contractor personne * QC inspection personnel were present at the work site and were observing the conduct of the activities

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Measuring and Test Equipment (M&TE) was properly calibrated and controlle * The procedure used to direct the work (Temporary Procedure (TP) 86-19, ATS Loop Test up Rack C2206 Transmitters) was properly approved, and adequate for the scope of wor * BECO and contractor personnel were familiar with the applicable procedure, and were knowledgeable of the work being performe * Adequate planning with regard to personnel required for the job, M&TE, QC personnel, communications equipment and coordination with operational personnel was demonstrated in an efficient manne * The inspector observed documentation of the work to be adequately performe In addition, tne inspector roviewed several recently completed contractor related work packages and maintenance requests in order _

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l i to further validate the above observations (See Attachmen~c 1 for { list of MRs reviewed). The results of this review further substantiated the observations listed abov No violations or deviations were observe .5 Maintenance Activities 3.5.1 Review / Implementation The inspector conducted a review of selected maintenance activities to determine if it was adequately documented; and to determine whether station maintenance practices result in quality maintenanc Applicable administrative procedures were reviewed in order to establish the programmatic framework, within which the inspector evaluated the conduct of station maintenance. The inspector selected a sampling of MR work packages to revie This review was conducted to verify the following attributes:

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Maintenance Requests (MRs) adequately described the work to be performe * QC had reviewed the work package prior to the initiation of any wor * MRs were properly authorized by the Operational Supervisor  ; prior to the initiation of wor '

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Description of the work performed was adequately recorded on the MR * Individuals performing the work are indicated on the MR * Maintenance procedures used for the performance of work are approved aLJ adequate for the work to be performe * Documentation throughout the work packages is adequat * Acceptance Criteria for post maintenance testing is specified and met, or evaluated and testing reperforme .5.2 Findings 3.5. The inspector observed that a large percentage of in progress MRs reviewed did not contain the Operating Supervisor's, " Approval to Start Work" signature. This matter was brought to the attention of management, who l _--

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addressed the inspector's concern of whether proper autho-rization was received for work prior to initiatio j Licensee management stated that the Operating Supervisor's J authorization is designated on the tagging order for indi- i vidual jobs. The inspector verified that proper authori-zation for each job reviewed was obtained prior to the  ; start of work, and that station administrative controls did j permit the final authorization to be specified on the 1 tagging order instead of the MR itsel The licensee subsequently stated their intention to ret' urn to using the Maintenance Request (MR) form as the final authorization for work. This programmatic change is ex-pected to simplify the paperwork for maintenance activi-ties, and would allow a modification of tagging control This tagging control modification would allow a single tagout to apply to various related jobs instead of requir-ing redundant tagouts for each individual job. The licensee stated that these programmatic changes would be instituted after the current outage in order to simplify the changeove .5.2.2 During the review of maintenance activities related to Motor Operated Valves (MOVs), the inspector determined that several post maintenance tests performed per Procedure No. 3.M.4-10, Attachment C, Revision 6, did not meet the acceptance criteria specified in the test documents. The inspector determined from his review and from discussions with maintenance and QC personnel, that although the tests did not meet the acceptance criteria, the test results were nevertheless approved as though the acceptance criteria had been me In particular, on Thursday, August 27, 1987, several examples were observed where recorded test voltages for MOV motors exceeded the acceptance criteria specified in test document For example, the inspector observed Maintenance Requests 86-273 (working MOV 1001-298) and 86-14-25 (work-ing MOV 1400-3A) to exhibit the following test data: MR # Acceptance Criteria Test Data Accepted 86-273 460 volts 480 volts 4/10/86 No tolerance 86-14-25 460 volts 520 volts 8/15/87 l No tolerance l l _ _ _ - - - _ _ . .

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l . 9 These discrepancies were discussed with licensee manage-ment, who were unable to demonstrate that these nonconfor-mances had been evaluated to determine the acceptability of the tests data. In addition, QC inspectors, who had reviewed the data did not identify the discrepancies or request corrective actio The licensee's failure to comply with the above require-ments is a violation of 10 CFR 50, Appendix B, Criteria XI and XVI (293/87-36-01).

3.5. In reference to the above violation, the inspector also identified a concern related to the effect of high voltages on MOV operating times. The inspector observed the closing time for MOV 1400-3A, as documented in the MR 86-14-25 work package, to be 86 seconds, 4 seconds below the specified acceptance criteria of 90 seconds and that the actual motor voltage was considerably higher than the acceptance criteria for motor voltage as previously discusse For this reason, the inspector questioned whether the valve clo v ng time would meet its acceptance criteria while the motor was operating at normal or degraded bus voltage which are lower than the voltages used in the test. The inspectors concern was based on the relationship between motor voltage,

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motor rotational speed and valve opening and closing spee The increased motor voltage may increase the valve closing speed enough so that the valve closing time may be met at 520 volts, but not at 460 volts. Discussion with the licensee revealed that no investigation of this effect had been performed, and that a similar problem may be present on other plant MOVs which require specific opening and closing time As an additional concern, the inspector questioned the licensee as to the effect of running 520 volts on lower voltage busses (460-480 volts). In particular, the inspector was concerned regarding the effect of high voltage on plant instrumentation, and calibration of protective relays and breake rs . The licensee was unable to provide an evaluation of these effects. Pending further licensee investigation and resolution, this item is unresolved (293/87-36-02).

3.6 Maintenance Requests (MR) The inspector reviewed applicable station documents and discussed with various Planning and Scheduling Section (P&SS) personnel the status of the station's MR backlog. The P&SS was established in early 1986 to plan, schedule and track site maintenance activitie Much of their initial effects were directed towards dispositioning a large backlog of MRs, many with an unknown statu _ _ - _ - _ - _ _ _ _ _ _

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L . 10 The licencee' has increased the staffing levels of the P&SS from an original level of 3 planners and one supervisor to the current level of 11 planners (3 lead planners, 4 mechanical planners, 1 I&C planner and 3 electrical planners), 2 parts expediters and one superviso An increase in staffing levels together with the develo.pment of various mechanisms utilized to schedule and track work activities has helped the licensee in attaining a manageable level of MRs. The maintenance group has set for themselves a goal of 500 or less MR During this inspection, the backlog of MRs stood at approximately 55 Performance indicators are presented to plant management on a weekly basis to graphically present trend development within certain key categories, one of which is the MR backlog. Also weekly meetings are held for Performance Excellence Team (PET) members to review the general trends of important categories, i.e., open MRs, plant decontamination, nonconformance reports, deficiency reports, et Overall the inspector found evidence of more careful planning and coordination of maintenance activities. MRs appear to be adequately reviewed, evaluated, prioritized, scheduled and tracked through completion of the work activit There were no further questions in this are . Quality Assurance and Quality Control of Maintenance Activities (QA/QC) 4.1 QA/QC Review / Implementation The inspector reviewed documentation and held discussions with QA/QC management personnel to assess the adequacy of QC involvement in the maintenance activities. The inspector also reviewed completed MRs for evidence of QC review before and after the completion of scheduled work. The organizational structure and staffing of the QC department was also reviewed to determine its independence and organizational freedom. QC procedures were reviewed for their technical content and clarity of instruction Based on the above reviews, discussions, and personal observations, the inspector determined the following:

 * The QC department is adequately staffed with qualified and experienced personnel to fulfill its responsibilit * All safety-related MRs are reviewed by QC to determine the adequacy of quality assurance requirements, and for establishing hold points and notification to QC before the start of the authorized wor . _ - _ . _ - _ _ - _ - - _ _ -

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All completed MRs of safety-related work are reviewed by QC before the closure to verify the completeness of documentation, adequacy of finished work, and compliance with acceptance criteri * The QC personnel also initiate their own inspection reports of the safety-related work covered by authorized MR * QC proce'dures are adequately detailed and clear to establish inspection requirement and procedural control for inspection and review activities performed by the departmen .2 Findings As detailed in paragraph 3.5.2.2, it was determined that inadequate reviews had been performed by QC, in that, test result data failing to meet specified acceptance criteria had not been identified during QC reviews. Also, as a result of QC failing to identify unacceptable test results, necessary corrective action had not been initiate .0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, a violation, or a deviation. An unresolved item identified during this inspection is discussed in paragraph 3.5. .0 Exit Meeting The inspector met with the licensee representatives (denoted in paragraph 1) on August 21, 1987 to summarize the scope and findings of the inspectio At no time during this inspection was written material provided to the licensee by the inspectors. Also the licensee did not indicate that any proprietary information was contained within the scope of this inspection, l ' I I

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ATTACHMENT 1 Documents Reviewed Administrative Procedures

* Procedure No. 1.8.2, PM Tracking Program
* Procedure No. 3.M.1-1, Preventive Maintenance, Rev. 3
* Procedure No. 3.M.1-11, Routine Maintenance, Rev. 5
* Procedure No. 1.3.5.1, Vendor Manual Review, Rev. 0
* Procedure No. 1.5.7, Unplanned Maintenance, Rev. 11
* Procedure No. 1.3.14, Training, Rev. 15
* Procedure No. 1.3.38, Plant Performance Monitoring Program, Rev. 1
* Procedure No. 1.5.3, Maintenance Requests, Rev. 21
* Procedure No. 1.3.31, Procurement of Items and Services, Rev. 2
* Procedure No. 1.3.20, Control and Utilization of Contractor Personnel and Contractor Supplied Material, Rev. 2
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Procedure No. 1.4.35, Personnel and Material Controls, Rev. O Maintenance Work Request Packages

* 86-10-108, Preventive Maintenance (PM) on "B" RHR
* 86-14-25, PM on MOV 1400-3A
* 87-46-155, Corrective Maintenance (CM) for Breaker 1025
* 83-46-290, Calibrate and Overhaul BKR 2023
* 87-3-231, Investigate CR0 Inoperability
* 87-3-215, Build CR0 8208
* 86-29-36, PM on MOV 3813
* 86-29-35, PM on MOV 3808
* 86-45-20, ATS Maintenance, Replace card LS-263-72-B1
* 87-10-137, Replace valve MD-1001-29B Miscellaneous
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Plant Performance Indicator Reports

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Material Condition Improvement Action Plan (MCIAP)

* MCIAP Summary Status of Restart Actions
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MCIAP Office Memoranda

* Plan of the Day (8/18, 8/19)          j l

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