IR 05000255/1985024

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)

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i U.S. NUCLEAR REGULATORY COMMISSION

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] REGION III  !

Report No. 50-255/85024(DRP)

Docket No. 50-255 License No. OPR-20 l 1  :

l' Licensee: Consumers Power Company j 212 West Michigan Avenue .

l Jackson, MI 49201 l Facility Name: Palisades Nuclear Generating Plant i  ;

l Inspection At: Covert, MI  !

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

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i Inspectors: Aj L. Madison

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T. E. Taylor

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J Approved By: Charles W. Hehl, Chief /'/2' M i Reactor Projects Date ,

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Inspection Summary ,

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! Inspection on September 30 through October 4, 1985 j l

(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-shift !

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

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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 inspectio 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, 198 . Action on Previous Inspection Findings (Closed) Violation (255/85003-01(DRP)). Two examples of inadequate corrective actions were describe (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 accomplishe 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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I 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 require '

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 require ;

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

i 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 procedure 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 Appendi 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

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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.

( This lack of adequate management attention to ensure :

j corrective actions is a matter of concern and is f

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

the Appendi (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 frequencie (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 don Through reviews of licensee documentation and interviews of licensec personnel, the inspectors determined that, when required, the procedural requirement was now being complied wit (2) A review of the licensee's compliance to Procedure 4.03

" Equipment Control" identified three instances of failure to follow p;rocedure (a) Procedure 4.03 required monthly review of the Jumper, Link and Bypass Control Log (JLBCL) which was not being performe 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 continuanc (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 modificatio The inspectors were concerned that timely actions had not been taken to adequately resolve this issu 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 manne Pending completion of all licensee actions, this item will remain open, (0 pen) Violation (255/85003-04(DRP)): Instructions provided on maintenance orders were not of sufficient detail for the type of activities being performe _ _ _ _ - _ _ _ - - _ _ _ - _ _ - _ _ _ - - _ _ _ _ _ _ - - - _ _ -

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

transmitter (LT) required by Technical Specifications without a [

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procedur 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 revision g. (0 pen) Open Item (255/85003-10(DRP))

Instrument calibration report for a digital multimeter (DMM) had a " final" adjustment criteria for i

the 1, 10, 100, 1000 VDC range less conservative than the "as found" l dat 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 equipmen The licensee has completed extensive roof repairs and caulking of

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

preventive maintenance program to ensure continued roof integrit No examples of equipment or cables being threatened by water leakage were foun f 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 r

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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 resolve . (Closed)OpenItem(255/85003-12(ORP)): Procedure 10.41 " Procedure on Procedures" failed to establish that the reviewer not be the originator of the procedur The inspectors reviewed Procedure 10.41 and verified that it had been revised to incorporate this requirement. No further actions are require (Closed) Violation (255/85003-15(DRP)): Failure to identify and l control shelf lif 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

, i 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 violation However, the licensee's

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review did not address the additional concerns raised by the inspectors concerning " dummy" purchase order !

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

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

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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, 198 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)).

' (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 require ' (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-relate :

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 require '

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 instrumentatio 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 repai 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 reductio 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 are This item will remain open pending reduction of control room work requests to a more reasonable leve 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 availabl 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 83-2 The i

review is still incomplete and this item will remain open pending

! completion and full implementation of the control progra 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" i

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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. (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 mechanism i

) 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 issu L

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

Four instances of significant ,

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

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

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

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l "significant" conditions adverse to qualit 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 noncompliance .

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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, Maintenance Backlog i i

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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 backlo This is

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not acceptabl 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  !

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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 worker '

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No violations or deviations were identified, i

4. Independent Inspection

' 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 I

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

! 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, i

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! 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 operation (2) Results in information, relied on by operators to take action, being inaccurate of indeterminat '

(3) Results in an annunciated control room alarm that reflects an j off-normal conditio !

1 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 ssfet !

j 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 abov l We further understand that following the 1985 refueling outage:

f 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 leve 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 backlo 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 outag 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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. 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 action The maintenance program at Palisades has noticeably improved in some area 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 operatio . 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, .n, 2.0, and . 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 proprietar