ML20137H492

Insp Rept 50-255/85-24 on 850930-1004.Violation Noted: Failure to Take Adequate Corrective Actions for Violations Re Overload Trip Device Maint,Procedure 5.03 & Trending of Corrective Maint.Confirmatory Action Ltr Issued

ML20137H492
Person / Time
Site:	Palisades
Issue date:	11/21/1985
From:	Hehl C, Madison A, Thomas Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137H456	List: IR 05000255/1985024 ML20137H452 ML20137H468
References
50-255-85-24, CAL, NUDOCS 8512020406
Download: ML20137H492 (11)

See also: IR 05000930/2010004

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i U.S. NUCLEAR REGULATORY COMMISSION

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] REGION III  !

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Report No. 50-255/85024(DRP)

Docket No. 50-255 License No. OPR-20 l

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l' Licensee: Consumers Power Company j

212 West Michigan Avenue .

l Jackson, MI 49201 l

Facility Name: Palisades Nuclear Generating Plant

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l Inspection At: Covert, MI  !

): Inspection Conducted: September 30 through October 4, 1985

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Inspectors: Aj L. Madison

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T. E. Taylor

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Approved By: Charles W. Hehl, Chief /'/2' M i

Reactor Projects Date ,

! Section 2A  !

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Inspection Summary ,

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! Inspection on September 30 through October 4, 1985 j

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(Report No. 50-255/85024(DRP))  ;

Areas Inspected

Special, unannounced inspection by regional inspectors of  ;

j licensee actions on previous inspection findings in the area of maintenance i

1 and Independent Inspection. The inspection involved a total of 68 inspector-  ;

] hours onsite by two inspectors, including eight inspector-hours onsite during I

} off-shifts.  !

, Results: One repeat violation was identified (failure to take adequate i

f corrective actions). Some improvement was noted, however, the lack of adequate i

l progress in the areas of trending and work order backlog was cause for concern. l

l A Confirmatory Action Letter was also issued as a result of this inspection, j

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DETAILS

1. Persons Contacted

Consumers Fower Company (CPCo)

R. Dewitt, Vice President, Nuclear Operations

• J. Firitt, Plant Manager

• J. Lewis, Technical Director

G. Slade, Executive Director, Nuclear Assurance

• R. Margol, QA Administrator

R. McCaleb, QA Director, Palisades

• H. Esch, Plant Administrative Manager

• R. Rice, Operations Manager

"D. Joos, Planning Director

• R. Orosz, Engineering and Maintenance Manager

• R. Vincent, Plant Safety Administrator

J. Alderink, Mechanical Engineer and Maintenance Superintendent

P. Bruce, Electrical Superintendent

• R. Fenech, Technical Engineer

• 5. Johnson, Licensing Engineer

• 0. Fitzgibbon, Licensing Engineer

• E. Dziedzic, Facility and Materials Superintendent

R. Brzszinski, Instrument Maintenance Superintendent

H. Tawney, Planning and Scheduling Superintendent

The inspectors also contacted other licensee personnel, as necessary,

during the performance of this inspection.

U.S. Nuclear Regulatory Commission

E. Swanson, Senior Resident Inspector

• C, Anderson, Resident Inspector

• E. Greenman, Deputy Director, Division of Reactor Projects

" Denotes those attending the exit interview on October 4, 1985.

2. Action on Previous Inspection Findings

a. (Closed) Violation (255/85003-01(DRP)). Two examples of inadequate

corrective actions were described.

(1) The first dealt with an Open Item (255n8025-01) which identified

the failure to perform preventive maintenance (PM) on the

480/460 volt switchgear and motor control centers. At the

time of the inspection the PMs were still not part of the

licensee's PM program and had not been accomplished.

The licensee has placed this equipment on the PM schedule,

but, has performed PM on a small percentage of the subject

equipment. This continued lack of management attention to

assure adequate corrective actions is a matter of concern and

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is considered a Violation (255/85024-01A(DRP)) as noted in the  !

Appendix.

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(2) The second example concerned the performance of biannual

procedure reviews. Through discussion with licensee personnel

1 and review of all plant procedures, the inspectors determined I

1 that the biannual reviews were up to date and that adequate

j mechanisms were in place to assure continued compliance. No i

! further actions are required. '

b. (Closed) Violation (255/85003-02(DRP)): Measuring and Test

i Equipment (M&TE) Improperly Controlled.

The licensee has revised the methods used to control M&TE and found

i them to be adequate. Through discussions with licensee personnel

i and reviews of selected records, the inspectors determined that M&TE

j is now properly controlled. No further actions are required.  ;

) c. (0 pen) Violation (255/85003-03(DRP)): Failure to follow procedures. ,

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1 (1) A review of the licensee's compliance to Procedure 5.03  !

j " Preventive Maintenance Program" identified three instances i

j of failure to follow procedures. l

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l (a) Procedure 5.03 required preventive maintenance trending l

yet none was performed. The inspectors determined that PM

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trending was still not scheduled or performed. This lack l

j of adequate management attention to ensure corrective  !

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actions is a matter of concern mi is considered a Violation  !

l (255/85024-01B(ORP)) as noted in the Appendix. l

Procedure 5.03 also required that a maintenance history be

maintained on equipment and that trending be performed

based on that history.

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The inspectors found that no machinery history was main-

tained and, therefore, no trending was performed. The

maintenance order forms were inadequate in format for use '

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as a machinery history and were filed in numerical order

! versus by equipment or system making them further useless

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as a machinery history. The licensee has revised this

j form and the revised form is very complete and contains

l the information necessary to provide an adequate machinery

i history. This form is computerized and thus provides

l sufficient flexibility for trending. However, the i

j inspectors discussed trending with maintenance management  !

j and determined that no plans had been formulated to perform [

! trending or for the necessary research to provide an

j adequate data base from the old maintenance order system.

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( This lack of adequate management attention to ensure  :

j corrective actions is a matter of concern and is

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considered a Violation (255/85024-01C(DRP)) as noted in *

the Appendix.

(b) Procedure 5.03 required that preventive maintenance be

performed within the prescribed frequency. The inspectors

identified several instances where PMs were beyond their

required frequency (including a 25% allowable time

extension).

Through reviews of licensee records, the inspectors

determined that with the exceptions noted in (1) (a)

above, the licensee's PM schedule was now maintained

within the required frequencies.

(c) Procedure 5.03 required that the reasons for failure to

perform preventive maintenance on schedule be documented

and provided to the Maintenance Superintendent. This was

not being done.

Through reviews of licensee documentation and interviews

of licensec personnel, the inspectors determined that,

when required, the procedural requirement was now being

complied with.

(2) A review of the licensee's compliance to Procedure 4.03

" Equipment Control" identified three instances of failure to

follow p;rocedures.

(a) Procedure 4.03 required monthly review of the Jumper,

Link and Bypass Control Log (JLBCL) which was not being

performed.

Throtgh review of licensee documentation and interviews

with licensee personnel, the inspectors determined that

mont'ily review of the JLBCL was now being accomplished

and that adequate controls were in place to ensure its

continuance.

(b) Two other examples related to the installation of a

bypass (e.g. lif ted lead) installed longer than a fuel

cycle that had actually become a permanent modification.

The inspectors were concerned that timely actions had

not been taken to adequately resolve this issue.

The inspectors reviewed the licensee's actions and found

that adequate management attention was being directed to

this area and that final resolution of this issue should

be accomplished in a timely manner. Pending completion of

all licensee actions, this item will remain open,

d. (0 pen) Violation (255/85003-04(DRP)): Instructions provided on

maintenance orders were not of sufficient detail for the type of

activities being performed.

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The inspectors discussed the violation with licensee personnel to

clarify the regulatory requirements. This violation remains open, i

4 pending further review,

e. (Closed) Violation (255/85003-05(DRP)): Root cause for equipment

malfunction not being documented.

Through review of completed work orders and the revised work order

administrative procedure, the inspector verified that the licensee's

program now addresses documentation of root cause. The inspector

also discussed with licensee personnel the terminology that should

be used (i.e. identify component such as " worn impeller" rather than

noting root cause as " normal use"). No further actions are required.

i f. (0 pen) Violation (255/85003-07(DRP)): Calibration of level

transmitter (LT) required by Technical Specifications without a [

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procedure.

The licensee has developed a " List of Maintenance Activities Within

the Normal Skills of Repairman." The list is in error and does not

fully comply with Regulatory Guide 1.33. The licensee has agreed to

further revise their procedures to comply. This item will remain

i open pending completion of those revisions.

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g. (0 pen) Open Item (255/85003-10(DRP)): Instrument calibration report

for a digital multimeter (DMM) had a " final" adjustment criteria for

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the 1, 10, 100, 1000 VDC range less conservative than the "as found"

l data.

l Further investigation by the inspectors determined that the "as

found" and " final" accuracies for the subject DMM were the same,

i However, the licensee believes that other equipment may be subject

to this discrepancy and is reviewing all calibrations to eliminate

this concern. Pending completion of said reviews, this item will

remain open.

1 h. (Closed) Violation (255/85003-11(DRP)): Poor housekeeping. During

tours of the facility the inspectors found several examples of poor

, housekeeping and unsafe storage practices. The inspectors also noted

that many roof leaks were allowed to exist for extended periods of

time that allowed water to leak onto class IE cable and equipment.

The licensee has completed extensive roof repairs and caulking of

, ceiling / building joints. Also, the licensee has implemented a

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preventive maintenance program to ensure continued roof integrity.

No examples of equipment or cables being threatened by water leakage

were found.

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The inspectors noted the overall improvement in general plant '

appearance that had addressed the specific examples cited in the

previous inspection and the underlying concerns expressed by the

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inspectors. Much has been done and much more is planned. The

licensee has achieved adequate performance in this area and as such

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this item is considered resolved.

1. (Closed)OpenItem(255/85003-12(ORP)): Procedure 10.41 " Procedure

on Procedures" failed to establish that the reviewer not be the

originator of the procedure.

The inspectors reviewed Procedure 10.41 and verified that it had

been revised to incorporate this requirement. No further actions

are required.

j. (Closed) Violation (255/85003-15(DRP)): Failure to identify and l

control shelf life. The inspectors had found two items controlled

, by " dummy" purchase orders which did not comply with shelf life

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criteria. A further review by the licensee found additional items

that did not meet shelf life criteria, l

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The inspectors reviewed the licensee's actions in this area and

found that the licensee had reviewed all " dummy" purchase orders for

shelf life criteria and had resolved all items identified as

discrepant. An inspection of the licensee's storage facilities

} did not identify any further violations. However, the licensee's

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review did not address the additional concerns raised by the

inspectors concerning " dummy" purchase orders.  !

l On June 15, 1984 an " Acceptance Plan Worksheet" was implemented to

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review products that were brought into the system under a " dummy"

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purchase order. This worksheet assured adequate review and

compliance with applicable regulations and standards. Prior to this

date no such review had taken place. It is the inspectors concern

, that products exist in storage which may be used in safety-related

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equipment that do not meet the required standards. The licensee

) agreed to review all open " dummy" purchase orders dated prior to

June 15, 1984. To ensure that no parts are released prior to

J completion of this review the licensee has placed a " hold" on all

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open " dummy" purchase orders prior to June 15, 1984. Completion of

this review will be tracked as an Open Item (255/85024-02(DRP)).

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k. (Closed) Open Item 255/85003-16(DRP)): Storage of safety-related

piping and sheet metal. These items are confined to one row in the

warehouse and are bounded by two large, lo;ked gates. However, the

sides of the row were open and made these gates ineffective. The

licensee has since properly secured this area and as such, no

further actions are required.

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l. (Closed) Open Item (255/85003-17(DRP)): Storage of flammable

liquids. The inspector found that the licensee was not confining

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all flammable liquids as required by ANSI 45.2.13(1976) specifically,

i those liquids regarded as safety-related.

j An inspection of the licensee's storage facilities verified that all ,

flammable liquids had been removed from the normal safety-related j

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storage area and confined as required. In addition, adequate

controls are now in place to assure continued compliance. No

further actions are required.

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m. (0 pen) Open Item (255/85003-18(DRP)): Reduction of the number of

open work orders on control room equipment. The inspectors were

concerned that the number of outstanding work orders on control room

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equipment (greater than 150) had an adverse impact on the operator's

confidence in their instrumentation.

The inspectors found that the number of open work requests on

control room equipment still exceeded 100. Further, the inspectors

found that these work requests received no additional attention and

3 in fact may receive less because of the power restrictions required

for their repair.

The number of open work requests in the control room was reduced

J to 99 by March 18, 1985 by eliminating unnecessary or redundant

I requests and working those work requests that could be accomplished

at 100% power. However, on September 30, 1985 the number was still

high (100) because no additional prioritization had been given these

requests to expedite their reduction. The inspectors are still

concerned that while the individual work requests are not

significant, their number negatively impacts on the operator's

1 confidence in control room equipment. The licensee agreed to place

increased emphasis in this area. This item will remain open pending

reduction of control room work requests to a more reasonable level.

3 See also paragraph 3.

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n. (0 pen) Open Item (255/85003-23(DRp)): No control of vendor

info rmation. Interviews with document control personnel and

maintenance planners indicated that the licensee had no formal

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control system to ensure that vendor information used for maintenance

i or testing activities was the latest information available.

The inspector found that the licensee is in the process of

implementing a review of vendor technical information. This review

is in response to this open item and Generic Letter 83-28. The

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review is still incomplete and this item will remain open pending

! completion and full implementation of the control program. i

o. (0 pen) Open Item (255/85003-25(DRP)): No formal controls for l

" blanket" work requests. The inspectors were concerned that without

formal controls over the usage of blanket maintenance orders,

inadequate maintenance and maintenance tracking / trending could be

l performed under their auspices.

! The licensee has revised their procedures to address "open"

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maintenance orders and provide adequate controls in all areas except

security. The licensee has agreed to provide controls in this area.

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This item will remain open pending implementation of these controls.

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p. (0 pen) Unresolved Item (255/85017-01): Inadequate trending of

Corrective Actions. This item was concerned with trending of

corrective actions as documented in Licensee Event Reports,

! Deviation Reports, and other similar mechanisms. i

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) The inspectors found that no fornal plans were in place to resolve  ;

) this issue. The licensee proposed implementing programs by the end l

of the second quarter of 1986. This is not satisfactory in light of

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the importance of this issue. The licensee has agreed to provide  ;

more timely resolution of this issue.

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q. (0 pen) Violation (255/85003-21(DTP)

Four instances of significant ,

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condition adverse to safety that were labeled " Observations" instead  !

of " Findings" thus not requiring response of followup to ensure l

] corrective actions.

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{ The inspectors discussed this item with members of the licensee's i

! staff. The licensee contended that these items did not represent '

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l "significant" conditions adverse to quality. It was the inspectors

position that the licensee should have had little dif ficulty ,

! classifying the cases cited, in that, had these items been identified  !

I by the NRC they would have been characterized as noncompliances. .

i This item will remain open pending further review of the licensee's  !

program for identification and control of corrective action.

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No other violation or deviations were identified.

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3. Maintenance Backlog

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l The licensee has made some effort to reduce the maintenance orders

l backlog. In March 1985, the number of open maintenance orders was

approximately 4000. That number is now approximately 2500 However, 50%  !

of that reduction has been accomplished by elimination of unnecessary or j

redundant work requests through cancellation or combination. For the  ;

period of March through September 1985, the maintenance order backlog i

has decreased by approximately 70 work orders per month. At that rate

it will take several years to adequately reduce this backlog. This is

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not acceptable. l

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j The licensee accomplishes an average of 300 work orders per month which

corresponds to average figures at other nuclear power plants. Plant

staffing appears adequate to accomodate the normal workload such that

j backlog numbers are not expected to increase. However, management needs t

j to redirect resources in order to effectively resolve the backlog issue  !

j in a timely manner.  ;

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! The licensee is currently undergoing financial difficulties and, as a l

' result of pay cuts and pay freezes, has experienced approximately a 20% j

turnover rate in personnel. This has reduced the level of experience in 1

i the maintenance department, and partially accounts for the slow turnaround

in addressing the backlog concern. The licensee is in the process of  !

) developing plans to attract new employees and provides incentives to

retain experienced workers. '

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No violations or deviations were identified,

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4. Independent Inspection

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a. The inspectors observed the performance of maintenance on

several occasions and noted the improvement in cleanliness

! control and the reduction in the spread of contamination. The

overall attitude of maintenance personnel has improved and is

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witnessed by the improvement of plant conditions and appearance.

! However, several poor maintenance practices were observed and

these were reported to management. The inspectors noted in one

j instance that maintenance personnel were performing work over

i the fuel pool area without securing tools and equipment. A

review of licensee procedures revealed that no formal

prohibition existed to prevent this except during refuel

operations. The licensee agreed to provide these controls.

This will be tracked as an Open Item (255/85024-03(DRP)).

b. The licensee has recently implemented computerized tracking of

Facility Changes (FCs) in order to maintain better control of

these. The licensee intends to institute a similar tracking

system for Specification Changes (SCs). Previously, it was

very difficult to determine the status of FC's and many remained

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open a considerable amount of time af ter completion of work or

remained unresolved due to part or engineering issues for

j extended periods.

j This system will provide management the necessary tool to

] better control FCs. However, no provisions have been made to i

! provide assurance that any actions will be taken to adequately

j and expeditiously resolve delays in closure. Implementation of  ;

i the tracking system for SCs and the addition of management

J controls to assure timely closure and resolution will be  ;

i tracked as an Open Item (255/85024-04(DRP)). '

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l No violations or deviations were identified. l

5. Confirmatory Action Letter l

To ensure continued management attention concerning the reduction of ,

the maintenance work order backlog and development of adequate

maintenance trending programs, a management conference was held i

telephonically on October 15, 1985 between Mr. J. F. Firlit of your

staff and Mr. E. G. Greenman of Region III. These issues were further

, discussed during a management meeting held at the Palisades site on

October 24, 1985 attended by Mr. J. Keppler and Mr. C. Norelius. The

j provisions of the resulting Confirmatory Action Letter are:

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A. Achieve a significant overall reduction in the current backlog of

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outstanding maintenance work orders (now is excess of 1700) by

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maximized staffing of the maintenance workforce during the upcoming

i refueling outage. The reduction will be achieved through a program

j which prioriti:es work according to its importance to safety with

j priority given work that can only be performed during an outage,

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B. Achieve a specific reduction (with a target of zero) of those l

outstanding control room maintenance work orders that: '

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(1) Directly affect the controls used by operators during emergency

situations, off-normal situations or routine operations.

(2) Results in information, relied on by operators to take action,

being inaccurate of indeterminate.

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(3) Results in an annunciated control room alarm that reflects an j

off-normal condition.  !

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C. Develop and implement trending programs to aid in the

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identification and assessment of root causes for system and

j equipment malfunctions, to validate the preventive maintenance

l program, and to determine the need for replacement or upgrading of

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installed equipment. These programs at a minimum will address the i

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following areas:

(1) Corrective maintenance - this trending program will include the

, development of a machinery history data base of one year for l

l safety-related equipment and for those systems important to  ;

safety.

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1 (2) Preventive maintenance - this trending program will include all

I safety-related equipment and systems equipment important to

l ssfety.

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j 0. Meaningful performance objects / milestones are to be developed and a ,

, monthly progress / status report will be prepared and submitted to the i

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NRC Region III office addressing progress with respect to Items A-C

l above.

l We further understand that following the 1985 refueling outage:

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E. The regular plant maintenance workforce will be augmented with

twenty (20) additional maintenance personnel plus supervisors. This

additional workforce will continue to reduce the work order backlog

to an optimal level. This optimal level will be determined by the

licensee utilizing input from INp0, other utilities and Palisades

plant historical data. A report will be submitted to NRC six months

following the refueling outage defining the optimum backlog.

F. The machinery history addressed in item C above will be extended to

include three years of history data six months following startup

from the 1985 refueling outage.

G. A progress / status report will be submitted every two months to ,

review progress on reducing:

(1) Work Order Backlog,

i (2) Control Room Deficiencies.

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6. Sumary

The inspectors performed a broad spectrum inspection of all maintenance

related areas as a followup inspection to the March 1985 Maintenance Team

Inspection. The purpose of the inspection was to review the licensee's

progress in resolving issues previously identified and to evaluate the

current status of the maintenance program at Palisades. Several problems

were discovered, as noted in the preceding paragraphs. The major areas

of continuing concerns were: (1) inadequate corrective actions by

management, (2) inadequate progress in reducing the maintenance order

backlog, (3) inadequate progress in reducing the number of control room

work orders, (4) lack of maintenance trending programs for corrective and

preventive maintenance, and (5) lack of adequate trending program for

corrective actions.

The maintenance program at Palisades has noticeably improved in some areas.

The system by which scheduling and planning of maintenance is accomplished

has been revamped and provides much more timely resolution of new mainte-

nance orders. The attitude of workers has improved significantly as

witnessed by plant appearance and equipment condition. The maintenance

order form has been revised to provide better tracking, greater flexibility

and a machinery history. However, the maintenance program at Palisades

overall continues to be progressing unsatisfactorily to resolution

and immediate management attention is required to ensure continued

safe operation.

7. Open items

Open items are matters which have been discussed with the license, which

will be reviewed further by the inspector, and which involve some action

on the part of the NRC or licensee or both. Open items disclosed during

the inspection are discussed in Paragraphs 2.c 2.d. 2.f. 2.g, 2.j, 2.m.

2.n, 2.0, and 2.p.

8. Exit Interview

The inspectors met with licensee representatives (denoted in Paragraph 1)

on October 4,1985, and summarized the purpose, scope, ant' findings of

the inspection. The inspectors also discussed the likely informational

content of the inspection report with regard to documents or processes

reviewed by the inspectors during the inspection. The licensee did not

identify any such documents / processes as proprietary.

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