IR 05000327/1987037
| ML20239A591 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/26/1987 |
| From: | Shymlock M, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20239A579 | List: |
| References | |
| 50-327-87-37, 50-328-87-37, NUDOCS 8709170507 | |
| Download: ML20239A591 (63) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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n REGION ll g , j 101 MARIETTA STREET, *' c ATLANT A, GEORGI A 30323 /
Report No /87-37 and 50-328/87-37
' Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: Jene 15 - July 31, 1987 Lead Inspec, tor: fa F'[.26/P7
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L. J. Wat' son, Team Leader D6te Signed Team Members: W. C. Bearden N. E. Economos R. D. Gibbs W. E. Holland R. M. Latta P. B. Moore C. J. Paulk W. K. Poertner Approved y: /I n ,
P/23/M 14 M'. B. 'Stymlock, Chief Dr a te' Signed Operational Programs Section Divisior, of Reactor Safety SUMMARY Scope: This special, announced inspection was conducted in the areas of maintenance and followup on open items involving maintenance, operations and ;
training activitie Results: One violation was identified involving failure to follow procedure for the repacking of two valves. No deviations were identifie j l
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0709170507 870909 PDR ADOCK 05000327 g PDR
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i REPORT DEIAILS 1 Persons Contacted l
I Licensee Employees
- C, C. Mason, Deputy Manager, Office of Nuclear Power
- J. 7 Lapoint, Deputy Site Director j
- G. L. Rogers, Office of Nuclear Power, Maintenance Manager
+*L. M. Nobles, Plant Manager
- E. R. Ennis, Assistant to Plant Manager
+*A. Qualls, Assistant to Plant Manager
+*B. M. Patterson, Maintenance Superintendent
- R. C. Miles, Unit 1 Startup Director
- T. J. McGrath, Assistant Nuclear Site Representative
+*G. B. Kirk, Compliance Licensing Manager
- H. D. Elkins, Instrument Maintenance Group Supervisor
- R. K. Gladney, Instr. ment Technical Section Supervisor
- C. W. LaFever, Assistant Instrument Technical Section Supervisor
- R. M. Mooney, Systems Engineer Section Supervisor
- D. H. Tullis, Maintenance Special Projects Supervisor
- M. A. Purcell, Licensing Engineer
- C. E. Cantrell, Corporate Maintenance Program Manager
- H. Sullivan, Supervisor, Plant Operations Review Staff
- A. Cooper, Con.pliance Licensing Engineer
- W. S. Wilburn, Assistant to Maintenance Superintendent
- A. H. Ritter, Lead Engineering Assurance Engineer
- J. W. Kelly, Engineering Assurance Engineer <
- R. N. Mays, Corporate Licensing Engineer
- T. A. Flippo, Quality Surveillance Supervisor j
- V. Phillips, Maintenance Coordinator
- E. Cribbe, Licensing Engineer f
- J. Akers, Communications Specialist
- Kontovich, Electrical Maintenance Technical Section Supervisor ,
- L. West, Assistant Electrical Maintenance Technical Section Supervisor '
+ V. Buchholz, Site Representative, Office of Nuclear Power
+ S. Kneidler, Plant Operations Review Staff, Engineer
+ Blankenship, Manager, Information Services !
+S. W. Litre 11, Environmental Qualification Coordinator l
+T. J. Arney, Quality Assurance Manager i
+D. L. Love, Craft Supervisor, Mechanical Maintenance ,
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Other licensee employees contacted included engineers, technicians, mechanics, and office personne l
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NRC Representatives
- F. R. McCoy
- R. C. Pierson
- K. M. Jenison' l
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- M. Branch
- P. E. Harmon
+*D. P. Loveless
- Attended exit interview on June 26, 1987 j
+ Attended exit interview on July 31, 1987 1 Exit Interview The inspection scope and findings were summarized on June 26, 1987 and July 31, 1987, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed In detail the following inspection finding (0 pen) Violation 328/86-37-01. Failure to Follow Procedure for Valve Repacking. (paragraphs 5 and 10)
The following items identified in previous NRC inspections.were also reviewe Items identified to the licensee as requiring completion prior to restart of Unit 2 are indicated below by the note " RESTART".
(Closed) Unresolved Item 327, 328/84-01-0 Two Year Review Cycle for Procedure Review. (paragraph 3.d)
(Closed) Violation 327/84-18-01, 328/84-19-01. Failure of Licensed SR0 to Participate in the Licensee's 1983 Annual Requalification Written Examination. (paragraph 3.a) ;
(Closed) Unresolved Item 327/84-18-02, 328/84-19-02. Return of Licensed Operator to Licensed Duties Following Six Month Absenc j (paragraph 3.e)
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(Closed) Unresolved Item 327/85-17-09, 328/85-17-08. Review j Licensee's Control of Sequence of Critical Steps in Proce.dures, j (paragraph 3.tj q l
(0 pen) Inspector Followup Item 327, 328/85-45-16. Masoneilan Valve l Failures. (paragraph 16.a) .j (Closed) Unresolved Item 327, 328/85-45-17. Operability of the UHI System in Light of Repeated Out of Technical Specification Tolerance Calibration Results. (paragraph 3.g)
(0 pen) Unresolved Item 327, 328/85-45-18. Seismic Qualification Documentation for Class 1E Components. (paragraph 3.h) RESTART l
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(Closed) Inspector Followup Item 327, 328/86-17-01. Completion of License Certification Lesson Plans. (paragraph 16.b)
(Closed) Inspector Followup Item 327, 328/86-17-02. Implementation of Expanded Annual Requalification Training. (paragraph 16.c) )
l (Closed) Inspector Followup Item 327, 328/86-17-0 Completion'of l Instructor Certification Program for Two Instructors. (paragraph 16.d)
(0 pen) Inspector Followup Item 327, 328/86-17-0 Pre-startup Training Commitments. (paragraph 16.e) RESTART (0 pen) Inspector Followup Item 327, 328/86-18-05. Update Applicable Procedures to Specify Torque Switch Settings for Applicable Motor Operated Valves (MOVs). (paragraph 16.f)
(0 pen) Inspector Followup Item 327,328/86-18-06. Review of Maintenance Instruction (MI) Enhancement Program. (paragraph 16.g)
(Closed) Unresolved Item 327, 328/86-18-07. Vendor Recommended Maintenance on Stored Equipment. (paragraph 3.1)
(Closed) Unresolved Item 327, 328/86-19-1 Stroke Time for UHI Isolation Valves. (paragraph 3.j)
(Closed) Unresolved Item 327, 328/86-26-0 Circuit Breaker Instantaneous Trip Testing Interpretation. (paragraph 3.k)
(0 pen) Inspector Followup Item 327, 328/86-48-02. Technical Support Systems Engineering Section Implementation. (paragraph 16.h)
(0 pen) Inspector Followup Item 327, 328/86-48-05. Complete Restart Maintenance Action. (paragraph 16.1) RESTART j (0 pen) Violation 327,328/86-49-91. Set Screws on the Upper Head Injection (UHI) Hydraulic Lock Release Valves. (paragraph 3.b)
(Closed) Inspector Followup Item 327, 328/86-60-1 Followup of Control of Stored Equipment. (paragraph 16.j) J (Closed) Inspector Followup Item 327, 328/87-15-01. No Followup Method to Ensure That the Safety Evaluation Report on M&TE Completed Within 14 Days. (paragraph 16.k)
(Closed) Violation 328/87-15-02. Failure to Follow Procedure M&AI-7 and the Failure to Provide Adequate Work Request for Replacement of Fire Retardant Coatings. (paragraph 3.c) j The following licensee identified items, documerted in the Nuclear Manager's Review Group (NMRG) report of December 17, 1986, were reviewe I L j
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Details of the review of'these items are.provided in paragraph 15 of this repor I Management and Corporate Involvement in the Maintenance Program i
Finding A-1 (Restart - Closed, Long Term - Open). Corporate l Responsibilitie Finding A-2-(Open). Performance Indicator Finding A-4 (0 pen). Adequate Root Cause Analysi Planning and Scheduling 3 l
Finding A-3 (0 pen). Corporate Guidance and Coordination of Maintenance Progra Finding C-1 (Closed). Training for Maintenance Planner Finding G-2 (Closed). Use of Current Revision of Procedures and Drawing Finding G-4 (0 pen). Coordination of Maintenance to Minimize Downtime, Testing and Radiation Exposur Finding G-5 (0 pen). Lack of Equipment Qualification Lis Finding N-2 (0 pen). Provide Hardware to Implement Effective i Maintenance History and Trending Program i Maintenance Procedures and Review of Maintenance Work Request System
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Finding F-1 (0 pen). Failure to Follow Work Instructions and Procedure Finding F-2 (0 pen). Finding H-7 (0 pen). Work Instructions Not Clear, Concise and Complet Preventive Maintenance Finding E-1 (0 pen). Finding E-5 (0 pen). Inadequacies in Preventive Maintenance Progra Finding E-3 (Closed). Lack of Management Approval for Waiver, Extension and Deferrals of Preventive Maintenanc Post Maintenance Testing (PMT)
Finding I-1 (Closed). edequate Definition and Performance of Post Maintenance Testin ,
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Quality Assurance
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Finding 0-1 (Closed). Plant Quality Assurance Reviews Were Not Identifying Significant Weaknesse '
Finding 0-2 (0 pen). Corrective Action for Items Identified by QA Not Effectiv Finding 0-3 (0 pen). Inconsistencies in Nuclear Quality Assurance Manua Deficiencies in the Rigging and Hoisting Program
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Finding L-4 (Closed). Rigging Identified as Defective Not l Segregated, t
Teflon Tape Usage ;
f Finding A-5 (0 pen). Unacceptable Usage of Teflon Tape as Thread Sealan Design Change Process Finding H-1 (Closed). Minor Design Changes Needed to Support Plant Maintenance and Operation are not Being Accomplished in a Timely Manne No dissenting comments ware received from the license The licensee did I not identify as proprietary any information reviewed by the inspector l l Licensee Action on Previous Enforcement Matters (92702) J
< (Closed) Violation 327/84-18-01, 328/84-19-01. Failure of Licensed SRO to Participate in the Licensee's 1983 Annual Requalification Written Examination. The violation involved an exemption from requalification written exams allowed by procedure for training instructor Exemption from annual exams for a licensed SR0 is not in accordance with 10 CFR 55, Appendix A.4.a. The inspector reviewed the training records for the individual involved and determined that the SRO had successfully passed the 1984 1 requalification exam and subsequent exams. The inspector also reviewed Area Plan 0202.05, Nuclear Plant Operations Training Program, Rev. O and OSLT-1, Nuclear Generating Plant Operator Training Program, dated February 12, 1987, and determined that these procedures had been revised to delete the exemptions. This item is ;
close ' (0 pen) Violation 327, 328/86-49-01. Set Screws on the UHI Hydraulic Lock Release Valves. The licensee committed to change SI-196, Periodic Calibration of Upper Head Injection System Instrumentation, via an Instruction Change Form (ICF). SI-196, Rev. 9, was changed I
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by ICF 87-160 to incorporate the necessary changes to resolve this 1 issue. Subsequently, ICF 87-541 was issued against this procedure f in order to answer Unresolved Iterns 327, 328/85-45-17 and 327, 1 328/86-19-10. The latest revision also incorporates changes to J ensure the set screws will not allow the hydraulic lock release
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valves to change positions due to vibration. This violation is included in issues being considered for escalated enforcement and therefore will remain ope i l
l c. (Closed) Violation 328/87-15-02. Failure to Follow Procedure M&AI-7 {
and the Failure to Provide an Adequate Work Request for Replacement 4 of Fire Retardant Coatings. The violation involved the removal of
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Flamemastic coating from penetration pigtails without procedural requirements for being returned to normal. The inspector reviewed
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the licensee's response of July 2,1987, which stated that a ,
Condition Adverse to Quality Report (CAQR) was initiated to document and correct the violation. The response stated that WP 12403 was revised to provide instructions for removing and replacing '
Flamemastic coatings, training sessions were held for procedural-compliance, and M&AI-13, Electrical Pressure Seal, Firestop Barrier, Thermo-Lag 330 Fire Barrier System and Flame Retardant Cable Coating l and M&AI-7, Cable Terminations, Splicing, and Repairing of Damaged'
l Cables were revised. The inspector reviewed CAQR SQP870250, dated l March 16, 1987 and attendance records for the. trainin No discrepancies were identifie In addition, Rev. 8 of M&AI-13 was reviewed and the inspector determined that instructions, precautions, and limitations for removing and replacing Flamemastic had been adde This item is close i d. (Closed) Unresolved Item 327, 328/84-01-03. Two Year Review Cycle for Procedure Review. The item involved the biannual review cycle established by OSTL-1, Nuclear Generating Plant Operator Training Programs, for required reviews of abnormal operating instructions (A0I) and emergency operating instructions (E01) by licensed reactor operators and senior reactor operator CFR 55 requires that >
these reviews be performed on a regularly scheduled basis. NRC policy established this interval as annually. The inspector reviewed the February 21, 1987 revision of OSTL-1 and determined that the subject procedure has been modified to require that each licensed operator review each AOI and E0I on an annual basis in order to maintain eligibility for license renewa This item is close I l (Closed) Unresolved Item 327/84-18-02, 328/84-19-02. Return of j Licensed Operator to Licensed Duties Following Six Month Absenc This item was closed in NRC Inspection Report 327, 328/86-17; however, the inspection report only indicated that the item was )
closed on Docket No. 328. The item was cited against both Dockets i Nos. 327 and 328. This entry serves to administratively close the item on Docket No. 32 j l
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' (Closed) Unresolved Item 327/85-17-09, 328/85-17-0 Review Licensee's Control of Sequence of Critical Steps in Procedures. The inspector reviewed procedure SI-102, Diesel Generator - Semi-annual Electrical Inspection, Rev. SI-102, which had been revised to I incorporate the instructions in MI-10.1, Diesel Generator i Inspection, had been revised tc correct the sequence of steps discrepancies. During the inspection documented in Inspection Report 327, 328/87-15, the inspector verified that ihe new procedure writer's guide in SQM -1, Sequoyah Nuclear Plant Maintenance Program, provided appropriate guidance for assuring steps were performed in the appropriate sequence. The inspector also reviewed a sample of procedures which had.been revised by the licensee for i startup as documented in paragraph No discrepancies were noted
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in the procedures regarding the control of sequence of critical step This item is close l 9 (Closed) Unresolved Item 327, 328/85-45-17. Operability of the UHI !
System in Light of Repeated Out of Technical Specification Tolerance !
Calibration Results. The licensee had requested Westinghouse to i perform an analysis on the data acquired during testing of the UHI i syste The results of the analysis were transmitted to the ,
licensee in letter TVA-86-703 dated October 23, 1986. The results !
showed that in all cases analyzed, the volume of water delivered I would have met that required by the Emergency Core Cooling System (ECCS) Loss of Coolant Accident (LOCA) analysis. The analysis also evaluated the valve stroke time and the stringent tolerance give Westinghouse determined that the stroke time should be changed from 1 3.5 +/- 0.05 seconds to 3.5 -0.14/+0.5 second J The licensee has replaced the Barton 288A switches in the UHI system on both units with Static 0-Ring (SOR) level switches. They have changed calibration procedure SI-196, Rev. 9, Periodic Calibration of Upper Head Injection System Instrumentation, via ICF 87-541 to reflect the change of switches. The revised procedure also tests the SORS at the pressure that would be pre ant during an accident.
, Subsequently, the licensee removed the SOR switches in response to IE Bulletin 86-02, Static 0-Ring Differential Pressure Switches, July 18,1986. The Unit 2 switches have been reinstalled, however, the Unit 1 switches will be reinstalled prior to Unit 1 start-up.
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valve stroke timing, it has been determined that the UHI system was l operable and would have performed its designed function. This item is close (0 pen) Unresolved Item 327, 328/85-45-18. Seismic Qualification Documentation for Class 1E Components. The licensee evaluated all l the components installed in the plant without the appropriate
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seismic qualification documentation. Items were identified which'
(1) required replacement, (2) did not require seismic qualification !
(non-class 1E), or (3) met seismic qualification criteria however :
documentation of acceptability needed to be provided. Not all of i those identified as requiring replacement had been replaced at the time of this inspectio This item will remain open until all items have been replaced and documentation verifie This is a RESTART ite i. (Closed) Unresolved Item 327, 328/86-18-07. Vendor Recommended Maintenance on Stored Equipment. This item was identified when the i
licensee was unable to produce objective evidence to verify that (1)
l inspection items required by PM 0909-317, Inspect Pump Assemblies, I were being accomplished on certain safety and non-safety related pump elements (parts) and, (2) that pump shaft rotation was ,
performed as recommended in vendor manuals. As discussed in NRC i Inspection Report 327, 328/86-48, the licensee was able to provide documentation in the form of AI-36, Storage, Handling, and Shipping of QA Material, data sheets and PM 1051-317, that fully described i the extent of preventive maintenance performed on the seven pump !
assemblies listed in PM 0909-317. Review of this information, I however, had reflected several discrepancies and concerns on preventive maintenance of stored components some of which appeared to be generic in nature, e.g. , storage activities and/or periodic ,
maintenance on certain equipment were not always in agreement with l manufacturer's recommendation I To correct the concerns / discrepancies on this issue and strengthen '
the preventive maintenance program, the licensee had undertaken the following actions:
1.) Issued new preventive maintenance (PM) instructions for pump elements, both safety and non safety related (PM 1051 317, implementation date August 15, 1987),
2.) Issued significant corrective action report SQ-CAR-86-46, dated November 5, 1986 with revisions to the corrective action and actions to prevent recurrence issued on March 13, 1987. The l report addresses the need to identify and implement special l storage requirements for material aging lif Completion dates for corrective action were September 30, 1987 and for actions to prevent recurrence June 30, 198 The inspector performed a walk through inspection of warehouse 13 to observe safety related components, e.g. spare pump elements, in Power Stores and thereby verify compliance with AI-36 and ANSI 45.2.2 requirements. Components observed were as follows:
Centrifugal Charging Pump SN NH44747 Proc Doc # 83P38-926241 Centrifugal Charging Pump SN NH45257 Shipping Doc # G236313 Safety Injection Pump Proc Doc # 83P38-926241 l
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s The selected items were inside shipping crates which showed no discernible evidence of physical damage. Similar walk through inspections were conducted in the Auxiliary Building, the diesel 1 generator exhaust fan room and the essential raw cooling water (ERCW) roo Components observed in these areas included: .
1 Containment spray pump 28-8
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Component Cooling Pumps 2A and 2B -
Centrifugal Charging Pump 28 .
Diesel Generator 2A-A Room Exhaust Fan 1A Diesel Generator 2A-A Room Exhaust Fan 2A {
ERCW DA Screen Wash Pump Motor l
Preventive maintenance records reviewed for adequacy included the following:
Inspection PM N Frequency Item l
0960-317, Rev. 1 Semi-Annual Safety-Related 480VAC Motors 1985, 1986, 7 99 HP and 1987 q 0515-070, Rev. 1 Annual Component Cooling System Pump 1985 and 1987 2A-A 1562-068, Rev. O Monthly Reactor Coolant Pumps - Unit 2 4/87 and 5/87 0509-072, Rev. O Annual Containment. Spray Pump 2B-B 1985 and 1986 1 1713-030, Rev. O Annual Auxiliary Feedwater Pump Room and !
11/18/86 Cooling Fan 1784-067, Rev. 1 Annual Essential Raw Cooling Water 11/17/86 Traveling Screen DA Motor ,
l 1810-030, Rev. 1 Annual Diesel Generator 2A-A Room ;
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11/17/86 Exhaust Fan IA Motor
Within these areas the inspector made the following observations:
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Both exhaust fans in the diesel generator exhaust fan room had loose fan belts which should have been replaced or tightene The licensee representative stated that the problem should have been identified by the person responsible for the daily / shift inspection of this area, and a work request issued on the equipmen No work request tag was observe The screen wash chain cover in the ERCW room was seeping oil ]
from one of the mechanically fastened seams. The presence of a white sealing material gave evidence of a previous attempt to temporarily arrest the leak. As in the case above, no work request ticket was posted on the equipmen One of four lugs / fasteners used to secure the inspection cover to the DA screen wash machine housing was missin No work request was poste These conditions were discussed with the cognizant engineer and the ,
inspector reviewed a copy of OSLA-99, Attachment C, Outside Routine !
Log, which identified inspection items which include fluid or !
lubricant leakage and belt condition. In this regard, the inspector reviewed the daily logs of inspection performed from June 13- 19, 1987 in this area and noted that no reference was made to the comitions observed. In that this matter did not appear to have significant safety implications, the inspector identified the concerns to the licensee for corrective actio The inspector determined that adequate corrective action had been taken to assure that maintenance on' stored equipment woM d be performed. This item is closed.
l j. (Closed) Unresolved Item 327, 328/86-19-10. Stroke Time for UHI Isolation Valves. As stated in paragraph 3.g., Westinghouse performed an analysis of the stroke time for UHI level switche The results changed the valve stroke time tolerance to -0.14/+ ,
second. The lower tolerance is the more critical in order to ensure i
that an adequate volume of water is injected. The procedure was changed via ICF 87-541 to include the recording of the hydraulic accumulator pressures. The procedure is currently being revised to further enhance its performance. Based on the results of the Westinghouse analysis and the changes made, this item is close (Closed) Unresolved Item 327, 328/86-26-02. Circuit Breaker Instantaneous Trip Testing Interpretation. The inspector had previously determined that the instantaneous trip feature of circuit breakers in SI-258 and SI-258.2, Testing of Molded Case and Lower ,
Voltage Containment Penetration Circuit Breakers, Unit 1 and Unit 2, j respectively, had not been teste The inspector reviewed SI-258 and SI-258.2, both Rev. 14, and determined that the instantaneous i trip feature was now required to be tested in accordance with a set
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of instructions provided in Attachment 4, Test Procedure for j l Instantaneous Element of Moldcd Case Circuit Breakers Using j Multi-Amp MS-2. The inspector also reviewed licensee letters dated ,
December 5, 1987 and December 29, 1987 to the NRC, which stated that )
testing of instantaneous trip features of. molded case circuit breakers was to be conducted; however, the licensee indicated that additional analysis of the exposure of molded case circuit breakers ;
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to potentially degrading voltage levels may be pursued in the future and a proposed Technical Specification submitted to the NRC to
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i reduce the number of breakers for which the instantaneous trip i
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feature was tested. This item is close . Unresolved Items Unresolved items were not identified during this inspectio ! Summary of Inspection Objectives and Conclusions The purpose of the maintenance inspection was to assess the current status of the Sequoyah maintenance program, review the corrective action; ;
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for open NRC items, review the status of Sequoyah Nuclear Performance Plan (SNPP) and Corporate Nuclear Performance Plan (CNPP) commitments and i review the status of corrective actions for the findings of the :
licensee's Nuclear Manager's Review Group (NMRG). !
The licensee stated in the Revised CNPP, Rev. 4, and in the SNPP, Rev. 1, !
that actions would be taken to prevent recurring maintenance problem These actions included the use of predictive techniques, improvement of i maintenance practices, and implementation of methods to ensure that !
problems applicable to more than one unit or site are identified and !
corrected. The licensee stated that a corporate staff would be i established to monitor the performance of the improved maintenance !
programs and assess adequacy. The licensee committed to upgrade the planning process for maintenance including defining the scope of l maintenance and ensuring that proper procedures and resources are
, available. In addition, the licensee comrcitted to (1) review and upgrade 4 operations, maintenance and surveillance procedures and (2) provide
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l increased management emphasis on the adherence to procedure The 3 licensee also committed to upgrade training of nuclear maintenance personnel, ]
j l i During this inspection, the inspectors noted that the licensee had made 1 noteworthy progress in the maintenance area. During the past two years, l
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the licensee had examined the maintenance process and had made changes which have improved the management and control of maintenance. The ,
structure of the maintenance organization had been evaluated and an !
improved organization structure had been implemented. The licensee had l made progress in changing the philosophy of the management of the l maintenance program from a reactive program to a program of preventive maintenance and predictive maintenance. Direct supervision of work in progress had also increase Management interest in maintenance program improvements had resulted in .
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the dedication of resources to the area, including additional staff; i plant engineering reviews; and, reviews such as the NMRG study and an
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equipment operability study. Support of the improvement initiatives has been evidenced by the dedication of the plant and corporate staff to achieve the necessary improvement Significant upgrades were noted in the following areas:
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l Planning and scheduli.ng Post maintenance testing Training of planners New maintenance work request system History and trending programs Craft review of work instructions Motor operated valve maintenance program Equipment qualification In addition, the NRC staff observed progress in establishing effective programs for preventive maintenance and corrective maintenance and in establishing clear assignments of responsibility and accountability.
During this inspection, the NRC staff confirmed that the plant had issued a comprehensive action plan for resolution of the NMRG findings issued in a report dated December 17, 1986 and had established tracking systems for restart and long term issues.
The inspection team identified one violation during the inspection involving the failure to follow procedure in regard to valve repacking.
The failure to follow procedures has been the subject of previous NRC violations, including a violation (328/87-15-02) in the last maintenance inspection, and was identified as Finding F-1 in the NMRG report on maintenance.
The inspectors discussed the root cause for the valve repacking violat' ion ;
with the licensee. The licensee interviewed all on-shift mechanics involved in valve maintenance to determine if the methods used to repack valves specified in the procedures were different than those actually used in the field. The licensee determined that a' skill-of-the-craf t ,
practice for assuring the correct dimension of the valve packing had been misapplied by the majority of the craftsmen, i.e., the mechanics had compared old packing to new to determine if the packing was correctly sized versus taking the dimensions of the stuffing box and the packing and determining that they agreed within +/- 1/64 inch as required by the procedure. The mechanics indicated that the procedure was not clear (in the requirement that the dimensions be measured by exact measurement versus an estimate) in that the procedure did not require that dimensions be recorded as is normal practice where an exact dimension is required.
The second. problem identified concerned application of a valve stem lubricant that had not been. verified as the correct lubricant by Quality Control (QC). Investigation of this problem indicated that the two mechanics involved believed that lubricating packing, including lubrication of the valve stem to ease packing insertion, was an accepted skill-of-the-craft determination. The mechanics involved stated that the material control form, a QC verified document, was reviewed by the.
mechanics for the proper lubricant type and that this verification was felt to be acceptable QC verification. The QC signature blanks in the work request package had been marked N/A by the planner, since the planner did not indicate that the work package was to include valve stem l lubricatio The mechanics interpreted.this to mean that the signoff was'
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not neede It was noted by the inspector that in the cases cited, packing of the correct dimension and the correct valve stem lubricant was used for the maintenanc In both cases, the mechanics observed during the inspection appeared to be confident that the procedures were being followed. All mechanics interviewed indicated that the need for procHure adherence had been stressed ir. training and stated that they understood and followed the requirement. The inspector noted that, in general, the licensee took strong disciplinary action when employees willfully failed to follow procedures and that craftsmen.were aware of this polic The conclusions reached by the inspector were that, due to past practices of relying heavily on skill-of-the-craft practices, the craft does not recognize in all cases where these practices conflict with the specific methods required in procedures and in some cases read these practices into the procedures. In addition, procedures are poorly written in some cases and do not provide the craft proper guidance on specific methods require The inspector discussed the corrective actions needed to resolve these problems with the licensee. The licensee stated that long term corrective action to improve procedures in the Maintenance Instruction Enhancement Program would be directed towards minimizing the gap between the procedure requirements and the interpretation by the technician, In the short term, the licensee stated that an investigation would continue and additional efforts would be made to determine all contributors to the problem. The licensee indicated that additional discussions would be i held with technicians and that technicians would be instructed to ]
specifically identify cases where an interpretation was involved to (
confirm with their managers that the practice used satisfied the '
procedural requirements. The licensee also indicated that procedure review methods, used to assure that the comments and concerns identified by craftsmen are collected, reviewed by appropriate individuals and incorporated in procedures, would be reviewed to assure that this process I expeditiously resolved procedure concerns. Communication between the j craft, foremen and supervisors was also cited as an area which needed to ;
be improved to assure that free communication of problems was promote ;
Procedural adherence in other maintenance activities observed was 1 adequate. The inspector believes that long term management emphasis will be needed to fully resolve the various aspects of tie procedural adherence problems. It appears that, at this point, the licensee has taken reasonable actions to address these problems in the maintenance are The SNPP indicated that inconsistent management involvement, accountability and control was the root cause of the problems in the maintenance area. Through interviews and reviews of resumes, the NRC staff observed that managers in the maintenance area are well qualified and are aware of their responsibilities in the implementation of the
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1 program. It was also observed that upper management, both plant and corporate, supported the implementation of corrective and enhancement effort However, during this inspection, the. inspectors.noted that improvements-are-still needed in the. management area. Specifically, management time devoted to adequately addressing long term program development was margina Improvements were needed,in. time management,
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j interface with support groups and stabilization of the corporate .
- j organization. These concerns were discussed with the licensee at the 1 June 26, 1987 exit interview and the licensee acknowledged the concerns ]
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l Subsequent interviews indicated that the licensee had..taken steps.in
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resolving these problems as evidenced by conducting a time study of 1 managers at the plant and. identifying problem areas. The licensee i indicated that this study involved evaluations of. management skills, work 1 processes, climate and stress factors, facilities and tools and that a report with recommendations on improving the' utilization of management . 1 talent would be provided to the licensee in the near future and evaluated !
for corrective _ actions. In addition, maintenance management appears to l be working with support groupsoto establish effective interfaces as evidenced by management planning meetings with QA and assignment of three SR0s, including the planning group supervisor, to the work planning l grou In regard to support gro_ups, the inspectors recommended to the licensee that attention ~be placed on expediting.the use of the System l Engineering Section in its intended function. .The inspectors noted l improvements in the. attention to long term program development and in l other areas during the inspe tion perio !
The inspectors noted that the permanent corporate organization is beginning to take shape with the hiring of two experienced managers. The inspectors emphasized during the exit interview the significant impact that the corporate organization could have on the. establishment'of an effective maintenance program. The NRC staff believes that stabilization of the corporate staff is essential to assuring = prompt implementation .of an effective long term program since many of the corporate decisions and guidance could result in rework' of programs if these decisions and-guidance are not provided in the early stages of developmen In aodition, the NRC staff noted several positions which are still' being filled with temporary staff. Use of temporary individuals was a contributor to management problems in the past. In' response to this concern, the licensee stated.that additional emphasis would be placed on naming the permanent staff members.to fill these positions and that a plant policy on filling positions expeditiously would be implemente I i
The NRC staff concluded that the licensee is addressing the management control of maintenance and although additional improvements ar j warranted, management of the maintenance program is adequate for restar '
The NRC staff reviewed the corrective.and preventive maintenance programs-and procederes. The inspectors noted during these reviews that
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procedures written to the writer's guide, i.e. , upgraded to the '
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procedures rewritten under the surveillance instruction review pro,s gram I were greatly improved. For other procedures, discrepancies were noted that could allow maintenance to be performed in an inadequate manner.
However, in most cases, review of the entire work request package c-indicated that other methods such as the planning effort or PMT guidance > I supplemented the procedures such that the discrepancies did not-result in inadequate maintenance. The details of these findings were discussed with the licensee and the licensee agreed to correct the specific deficiencies. The licensee corrected most of the errors during the inspection period.
In light of the finding that procedures can be supplemented adequately in {
the short term by the planning process requirements and management '
controls; and, recognizing the craft review requirements and the management directive to stop work if deficiencies are identified in a maintenance procedure during performance, the NRC staff concluded that ,
pursuit of the comprehensive review of these procedures in accordance I with the licensee's Maintenance Instruction Enhancement Program (MIEP)
would be more beneficial than expending manpower in a brief technical adequacy review in the short term. The MIEP appears to be a comprehensive program which will correct both the technical and useability problems.
To address this finding, the licensee committed to provide a submittal to the NRC, by August 14, 1987, which describes the Maintenance Instruction Enhancement Program including: '
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a commitment to finalize the writer's guide to assure that consistent guidance is utilized throughout the enhancement effort,
- details of the scheduling of the plan,
- firm commitment dates for completion of the enhancement of the maintenance instructions, and
- the validation and verification program for enhanced instruction l The NRC staff will review this submittal and determine if the long term plan represents an acceptable method to control the resolution of '
procedural deficiencies to allow restart of the unit i The inspectors reviewed the commitments in the SNPP, Rev. 1,Section II.4.0, and determined that the licensee had implemented actions to address all items in the submittal with the exception ofi he t validation and verification program for the Maintenance Insif05 tion l Enhancement Program. The licensee stated that the validation and- '
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verification program was being developed and information on the program would be provided in the August 14, 1987 submittal to the NR '
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The inspectors emphasized at the conclusion of the exit interview that the licer.see still has restart items to be accomplished in the J maintenance area prior to startup. These items include the completion of )
the restart maintenance procedure revisions, completion of' actions to j address the equipment condition study, c mpletion of corrective actions gl for NRC findings 85-45 18, 86-48-05 and 86-17-04, resolution of restart . s, , !
items from the FSArt and TS review and maintenance upper tier document
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a s j assessment, completion of restart corrective actions for NMRG findings in i NMRG Audit Report No. R-87-02-SQN dated December 17, 1986 as described in the site Corrective Action Plan dated May 12, 1987 and corrective actions .
-for the NMRG re-audit dated June 12, 1987. Status of these efforts will be reviewed by routine NRC inspection activities and by the NRC restart review tea In summary, the conclusions of this inspection reflect that, with th ,
f completion of corrective action programs for restart and establishment of the details of the Maintenance Instruction Enhancement Program withstheL August 14, 1987 submittal, that the established maintenan.e program'wfl l support restart of Unit 2, Review of Management Control of Maintenance Program (62702)
The SNPP, Rev.1, Section 4.0, Maintenance, states that the underlying \
root cause of the maintenance program deficiencies was the " lack of management attention as evidenced by inconsistent management involvement, accountability, and control of maintenance." The inspectors reviewed ;
I various aspects of management control to verify that management !
initiatives including management involvement in day-to-day maintenance activities, clear delineation of responsibility and accountability, and management control of maintenance have been completed or the licensee has !
developed appropriate corrective action programs including long term (
l enhancement programs to assure that the management of the maintenance !,
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program is adequate. The items reviewed included the commitments in the l SNPP, Rev. 1, and the CNPP, Rev. . Corporate Involvement in Maintenance '
Historically, the Machanical Services Branch and the Electrical and '
Instrumentation and Control Branch of the Division of Nuclear Engineering (DNE) were the corporate' organizations assigned to assist the plants in maintenance activities. These organizations t were later combined into a subdivision, Operational Engineering -
Services (OES) in the Division of Nuclear Engineerin The licensee committed in the CNPP and the SNPP to increase the U i direction provided to the plant from the corporate organization in
, the maintenance area. A new position in the corporate organization l has been designated as a Division. level manager reporting to the l Manager of Nuclear Power. The inspectors interviewed the individual ,
selected as the Corporate Maintenance Manager. This individual had
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.h a one year contract with the licensee, but appeared to have i - '
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excellent credentials. The licensee had also recently selected a permanent employee to take over this positica. Details on how the permanent licensee employee would assume the position are still under development by the licensee.
The Corporate N; clear Maintenance Manager is directly responsible for the development and implementation of an improved maintenance program and maintenance policies and directives for all nuclear plants owned by the licensee. This position elevates the stature of maintenance and provides an indication of corporate management attention and direction to the nuclear maintenance program.
Under the new Corporate Nuclear Maintenance W nager, staff from OES will be utilized; however, the structure of the new organization had not been finalized. The Corporate Nuclear Maintenance Manager had been in the position for approximately 1 month when interviewed and stated that his goal for finalizing the structure of the new organization was approximately one mont Individuals for the new staff would then be selected. Until that time the OES staff is working with the Corporate Nuclear Maintenance Manager to finalize the new Oivision Directive on maintenance and to assist in other projects.
The inspectors were provided copies of the following studies of maintenance performed at Sequoyah by OES. Memorandum from C. R. Favreau, Supervisor, Maintenance Program Assessment and Equipment Condition Evaluation Project, ONP, to B. M. Patterson, Maintenance Superintendent, ONP, Equipment Condition Evaluation Report, dated February 11, 1987. Memorandum from C. R. Favreau, Supervisor, Maintenance Program Assessment and Equipment Condition Evaluation Project, ONP, to B. M. Patterson, Maintenance Superintendent, ONP, Equipment Condition Evaluation Report, dated March 9, 1987. Memorandum from C. R. Favreau, Supervisor, Maintenance Program Assessment and Equipment Condition Evaluation Project, ONP, to R. A. Sessoms, Acting Manager of Operations Engineering *
Services, Sequoyah Nuclear Plant (SQN) - Maintenance Program l Assessment, dated April 15,-1987.
The maintenance program assessment, conducted in early 1987, included a review of the plant maintenance program administrative procedures against the requirements of the draft corporate maintenance directive, dated November 20, 1986, and applicable sections of the Nuclear Quality Assurance Manual (NQAM). The plant procedures reviewed in the assessment included:
SQM-1, Sequoyah Nuclear Plant Maintenance Program, Rev. 9 SQM-2, Maintenance Management System, Rev. 24
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i SQM-57, Preventive Maintenance Program, Rev. 7 SQM-58, Maintenance History and Trending, Rev. 6 SQM-62, 10 CFR 50.49 Program: Qualification Maintenance Data Sheets (QMDS) Implementation, Environmental Qualification Deviation Report and Category II Upgrade, Rev. 3 SQE-8, Control of Installed Permanent Process Instrumentation, Rev. 3 i SI-1, Surveillance Pregram, Rev. 19 i AI-14, Plant Training Program, Rev. 37 l The assessment endorsed the use of plant procedures listed above as interim procedures for Sequoyah startup and operation until the higher tier corporate maintenance directives and standards were finalized and issued for use. The assessment identified several areas where the plant procedures did not' adequately address the corporate directive or the NQAM. Significant areas icentified for correction included training for planners; lack of a master list for l safety related equipment; no automated integration of the Work j Request, Preventive Maintenance (PM) and Surveillance Instruction programs; na adequate guidelines for planner for implementing post maintenance testing; no adequate guidelines on when root cause/ failure analysis is required; and, predictive maintenanc !
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The inspector noted that the issues identified reflect those issues which had been identified for correction through other reviews such as NRC inspections and the Nuclear Manager's Review Group maintenance review. The inspector reviewed the mechanisms the licensee is using to assure that the deficiencies in these administrative control procedures are being correcte The licensee has included these items in the Management Action Tracking Syste !
i No violations or deviations were identifie j b. Organizational Changes and Manager Qualification Review The inspector reviewed the organizational changes identified in the SNPP in order to determine their effectiveness. In particular, the i i
inspector compared the commitments contained in the SNPP and CNPP to the current organiz: onal chart and determined that the licensee had permanently filled the majority of the maintenance management i position Plans to fill all maintenance management positions were 1 discussed with the licensee. The use of temporary individuals to fill maintenance positions when managers were in extended training q or assigned to special long term projects was a contributor to J management problems in the past. In response to 'his concern, the licensee stated that additional emphasis would be placed on naming the permanent staff members to fill maintenance positions where temporary managers are currently assigned and that a plant policy on filling positions expeditiously would be implemente The inspector also reviewed the qualifications of selected I
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maintenance managenent personne The qualifications of the individuals examined in all cases exceeded the requirements specified in ANSI 18.1 - 1971 as endorsed by Regulatory Guide 1.8, 1 Revision 1-R. The inspector also reviewed the position descriptions of all maintenance managers and determined that they appeared to be comprehensive and definitiv During this inspection, interviews were conducted with the following corporate level and plant maintenance management individuals:
Manager, Corporate Nuclear Maintenance Licensee designee for Manager, Corporate Nuclear Maintenance ;
j Manager, Maintenance project i
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Assistant to Site Director Plant Manager Maintenance Superintendent 1 Manager, Mechanical Maintenance Group j Manager, Electrical Maintenance Group i
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Manager, Instrument Maintenance Group General Foreman, Mechanical Maintenance Support Supervisor, Mechanical Craft Section i Supervisor, Electrical Project Coordinator Supervisor, Electrical Engineering Section Supervisor, Electrical Craft Section Supervisor, Instrument Maintenance Surveillance Instruction Review Supervisor, Mechanical Maintenance Section Supervisor, Instrument Technical Section The inspector determined that these individuals were aware of their responsibilities and were committed to maintenance program 1 improvements.
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l The inspector reviewed both management and staff resources currently
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allocated to the administration of the Sequoyah maintenance program and determined that the permanent staff appears to be adequate to control and implement the planned maintenance. Specifically, the inspector reviewed the staffing plans for the Mechanical, ,
Electrical, and Instrument Groups and determined that the use of contract personnel was primarily limited to the procedure enhancement of maintenance instructions (mis), surveillance instructions (sis) and preventive maintenance instructions (H4s).
In order to determine if appropriate supervision for contract personnel was provided and that contractors are adequately trained, the inspector examined the Instrumert Maintenance Surveillance Instructions upgrade group. This group, which was formed expressly for the procedures enhancement effort, is comprised of approximately
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38 i~11viduals of whom 20 are contract personnel including 4 1 clerkal aides. The inspector reviewed the qualification of 5 ]
contract personnel and determined that these individuals appeared to /
have adequate experience in the field of technical procedure development. Formal training had been provided in the form of a two hour familiarization course plus specific on the job training by ,
experienced procedure reviewers. Generic guidance in procedure j development was also provided to contract personnel in the form of written procedures; SI-1, Surveillance Program, Rev. 20, AI-4 l Preparation, Review, Approval and Use of Plant Instructions, Re , and SQM-1, Sequoyah Nuclear Maintenance Program, Rev. 1 The i inspector also determined that following rewrite, all surveillance !
instructions are examined by four senior reviewers. Two of these reviewers are permanent TVA employees and two are contract personnel. The inspector reviewed the resumes of three of these l reviewers and determined that their qualifications and experience appeared adequate to fill these position Within the area of management of staff resources allocated to the administration of the Sequoyah maintenance program, the inspector determined that the licensee's commitment appeared to be adequat However, the inspector did note that the manager to staff ratio in the mechanical, electrical, and instrument engineering sections appeared low and that the work load in these sections was very hig It is recommended that the licensee evaluate this situatio No violations or deviations were identified.
d. SNPP and CNPP Commitments The inspector reviewed the commitments in regard to management of the maintenance program identified in the SNPP and CNPP and evaluated the implementation plans to determine the status of program completion. In particular, the inspector reviewed the corrective measures designed to rectify the licensee identified inconsistent management attention and involvement in control and accountability of maintenanc The inconsistencies in management practices appear to be attributable to the cumulative effects of a reactive posture adopted by the organization in response to combined reorganizational efforts and the pressures to complete the_ rapidly emergent maintenance backlo The reorganized maintenance department appears to have made significant progress in overcoming the subject management deficiencies and is currently focusing on the implementation of consistent direction. This task has been accomplished by the application of augmented resources in the form of new management positions and increased staffing levels. These include the addition of a Maintenance Project Coordinator, a Preventive Maintenance .
Manager position, two Support General Foremen, one Lead General )
Foreman, two General Foremen positions, several additional staff
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1 personnel and additional site engineering support staf The inspector determined that corporate management attention has been directed at the maintenance nrogram in that, as recommended by the Nuclear Manager's Review Gr % , a Corporate Nuclear Maintenance t
. Manager position has been established. This manager will be responsible for developing and implementing improved maintenance
. programs and policies at all TVA nuclear plants. The target date l for establishing a staff reporting to the Corporate Nuclear Maintenance Manager is in the August / September 1987 time fram In concept, each nuclear site will remain responsible for planning, j scheduling, and executing its own maintenance and the Corporate Nuclear Maintenance Manager and his staff will be responsible for regular assessment of the effectiveness of site maintenance. The j assessment process is linked to the develcrment of corporate {
policies, directives, and standards. As previously stated in NRC ]
Inspection Report 327, 328/87-15, a corporate policy statement on maintenance, ONP Policy No. 10.3, Revision 0, and a draft copy of the corporate directive on maintenance, ONP-DIR-10.3, Revision 0-C, were examined and appeared to be generally acceptable. However, until the corporate directive on maintenance and standards on maintenance to invoke the corporate policy statement are approved i and issued Finding A-1, Category 3 of the NMRG report, which is considered a long term action item, will remair ope Site management involvement in the maintenance upgrade effort is exemplified by the organizational changes previously described and i on the internal development and incorporation of performance based l accountability, enhanced communications, procedural adherence policies and increased management involvement in daily activitie As determined by the inspector, performance based accountability is emphasized within the maintenance department by the use of employee performance reports. These reports as documented in NRC Inspection Report 327, 328/86-48 are used at the craft level to identify J exemplary performance as well'as documenting disciplinary actio Performance reports of craft workers are reviewed by foremen and general foremen throughout the year and are used to provide .
evaluative input fc' annual appraisals and merit pay increase The 1
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craft foremen are also instructed to initiate investigations of personnel error by their crews to ensure the timely gathering of pertinent informatio Corrective action for one deviation (327, 328/86-48-01) in this area was completed and the deviation closed in !
NRC Inspection Report 327, 328/87-1 j Accountability is also stressed w' thin the maintenance organization by holding the general foreman responsible for the completion of maintenance and work requests including the quality of the final i work package Further delineation of accountability is reinforced i by assigning responsibility for the performance of each surveillance i-I l
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instruction to designated foremen in the instrument maintenance group and in the mechanical maintenance group. Within the electrical maintenance group, specialized crews are used repetitively on similar assignments; thus increasing their efficiency and establishing their accountabilit The maintenance department also has utilized the Sequoyah Foreman's Handbook as an aid to their foremen in identifying responsibilities concerning safety, security, health physics, organizing and l
controlling crew activities, and the importance of job site visits.
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The SNPP had indicated that inconsistent management involvement, accountability and control was the root cause of the problems in the maintenance are During this inspection, the inspectors noted that i improvements are still needed to assure that management time is )
devoted to adequately addressing long term program developmen Interviews indicate that the licensee has taken the first steps in resolving these problems as evidenced by conducting a time study of !
managers at the plant and identifying problem areas. The licensee indicated that this study involved evaluations of management skills, work processes, climate and stress factors, facilities and tools and that a report with recommendations on improving the utilization of management talent would be provided to the licensee in the near future and evaluated for corrective actions. In addition, the licensee had identified interface problems with other organization Maintenance management has addressed these problems by working with support groups to establish effective interfaces as evidenced by management planning meetings with QA and assignment of three SR0s, including the planning group supervisor, in the work planning proces The inspector reviewed the April 28, 1987 report to the Manager of Nuclear Power on the status of corrective actions in the maintenance program. This document was titled, " Quarterly Status Report -
Maintenance Corrective Actions - Nuclear Manager's Review Group (NMRG) Report No R-86-02-NPS", and included an executive summary and update on actions completed and planned to resolve each of the NMRG finding The inspector determined that the cumulative efforts to formalize management involvement, accountability and control have contributed I favorably towards enhancement of the maintenance program at -l Sequoya Inadequate communications to the working level by management of job requirements, performance expectations, and feed back was also identified as a major contributor to the SNPP finding of t inconsistent management involvemen As documented in NRC Inspection Report 327, 328/86-45, the commitment in section 6.3.1 of the SNPP to improve such' communications by implementing weekly meetings among the maintenance group supervisors, craft section i
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l supervisors, foremen, and general foremen .as well as weekly crew safety meetings and monthly safety meetings in which plant policy issues are discussed has been implemented. In order to verify the corrective measures accomplished by the licensee to enhance a communications between working levels, the, inspector attended a {
meeting of the electrical craft section manager and his craft !
foreman and planners on June 19, 1987. This meeting appeared well ,
structured and was adequately controlled. Status updates from the {
craft foremen emphasized procedure compliance, coordination of shop
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activities, restart priority issues, safety concerns, shift manning
, and the importance of open communications. Based on the
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I thoroughness with which issues were discussed in.this meeting and interviews conducted with both craft workers and craft foremen, the inspector determined that the licensee commitments stated in SNPP for routine scheduled meetings were being satisfie I To further strengthen the mechanical maintenance section, changes have been made in the engineering section which include an engineering section responsible for major maintenance work and refueling / outage support activitie ;
I Additionally, the resources of the Systems Engineering Branch, j formerly the Reliability and Performance Branch, are available to the sit This branch is a part of OES which reports to the Division of Nuclear Engineering and although it is currently staffed, its functional responsibilities of assisting the sites in the development of a preventative / predictive maintenance program have not been implemented. The role of this staff was described in Standard practice SQA-168, Systems Engineering, Rev. I Responsibilities of a systems engineer include task leader for ]
problem solving and projects,' test director, primary plant contact 1
! and systems technical expert on specific systems. Engineers in other organizations are also detailed as systems engineers in -
accordance with SQA-168. The inspector did note that this branch !
has been involved with the site and is credited with numerous 1 contributions including: the development of a sys+.ematic equipment l condition evaluation prosram, providing operational experience 1 reviews, assistance in the control of erosion, corrosion control in '
carbon steel piping, revised guidance in the ISI program, assistance in EQ issues and various other support activities requiring l
technical support and direction. Although positive indications of ;
the accomplishments of OES are evident, the effectiveness of this '
organization under the new mandate of the corporate nuclear maintenance manager cannot be fully evaluated at this tim Implementation of the Systems Engineering Branch functions had been identified as Inspector Followup Item 327, 328/86-48-02. This item remains open. The licensee stated that the Systems Engineering
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Branch was being phased into the maintenance program and reconfirmed that the goal for implementation of an engineering assistance program that was system based was prior to startup. Full implementation of this program is not considered a restart ite _ ________.__-_______.__m_______ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _
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No violations or deviations were identifie . Corrective Maintenance Program Assessment (62702)
The inspectors reviewed the corrective maintenance program to determine if programmatic controls were in place, maintenance work requests'and procedures were controlled and new maintenance history trending programs were identifying recurring equipment failures and correcting these problem The inspectors reviewed portions of the following procedures:
SQM-1, Sequoyah Nuclear Plant Maintenance Program, Rev. 10 SQM-2, Maintenance Management System, Rev. 24 SQM-58, Maintenance History and Trending, Rev. 6 SQA-199, Site Daily Work List, Rev. O SQM-66, Post Maintenance Testing, Rev. O AI-20, QC Inspection Program, Rev. 14 AI-3, Clearance Procedure, Rev. 34 The inspectors determined that SQM-2 provided the programmatic controls for initiating requests for routine and emergency maintenance and specified the criteria and responsibilities for review and approval of maintenance activities, designation as CSSC or non-CSSC, and performance of work. AI-20 and SQM-2 contain provisions for inclusion and performance of QC holdpoiats. AI-20 had been updated to include the use of CAQRs and to upgrade the inspection process by. requiring inspection plans to control and document QC inspection The inspector reviewed SQA-199, which was issued on June 17, 1987, to provide better control of the scheduling of maintenanc The inspectors j noted during the review of maintenance in progress that problems are j still occurring in the coordination of the various aspects of maintenance resulting in work delay No problems were noted in the quality of maintenance due to these delays. The inspectors noted several !
maintenance activities that were scheduled for work in the daily work list yet.were delayed due to late issuance of radiation work permits or failure to obtain a clearance for the wor The inspector discussed l these items with the licensee. The licensee stated that they were aware '
of these problems and were taking action to resolve the conflicts and improve implementation of the new program. The licensee stated that scheduling for the foreman level was to be provided in the near future including estimates of manpower needed and requirements for additional management attention to the progress of the work'.
The inspector reviewed the administrative controls for documenting maintenance activities and determined that appropriate records including approval of the work request, authorization by operations for start of work and notification of- results, identification of planners, technicians and individuals who performed the work and post maintenance testing
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(PMT), cause of failure, corrective action, PMT requirements, replacement parts and measuring and test equipment are required by SQM- j l
The inspector reviewed the administrative controls for post work !
evaluation and control. SQM-2 contains a program for review of completed WRs including a requirement for QA review of all completed CSSC package In addition, a program to retain documentation of CSSC maintenance was in ;
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The WR form contains a checklist for determining if special processes are !
involved in the maintenance and if fire protection provisions are needed or affected. SQM-2 does not provide guidance on the procedures to be i used to address these special requirements. The licensee stated that I planners and foremen are aware of these procedures but that a revision was in progress to provide additional guidance to planners on the appropriate procedures to enhance the planning process. The licensee provided a list of the procedures which cover the checklist item The inspector reviewed AI-3, Clearance Procedure, Rev 34. The procedure appeared to provide adequate controls for issuance o' clearances and restoration of equipment held under clearances. The inspector reviewed all clearances on the Unit 2 Main Control Board. All of the clearances ,
were properly executed and were accurately documented in the control room J clearance log. The inspector identified one concern in the quarterly l l review of clearance records. AI-3 requires that clearances be I renumbered and completely verified on January 1 of each yea On April 1, l physical verification of ten percent of the clearances is required.
l On July 1, physical verification of all clearances older than 6 months is required. The inspector noted that the operators had performed a
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l physical verification of the same clearances each time except for those l
clearances canceled during the period. The inspector discussed this j concern with the licensee who acknowledged the concer The inspectors observed housekeeping in various areas during the maintenance inspections. The inspectors noted that the licensee has l targeted certain parts of the plant for extensive cleanup and refurbishing activitie These areas demonstrated excellent housekeepin However, other areas of the plant including pipe chases on EL 690 and Unit 2 cold leg accumulator room #4 exhibited poor housekeepin The licensee was advised of these areas and housekeeping techniques were discussed. The inspectors noted that housekeeping was a signoff on all work requests, however, this measure did not appear to be effective in the areas mentioned abov i The inspectors reviewed the administrative controls for assuring that
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revisions to vendor manuals are incorporated into maintenance procedure The inspectors determined that the procedure did not properly document the distribution of revisions to vendor manuals in that the actions taken to incorporate vendor manual revisions were not tracked or completion confirmed. The inspector discussed this concern with the license The licensee indicated that AI-23, Vendor Manual Control, was being updated
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revised to document the review of procedures for changes due to vendor manual revision The inspectors noted during the program review that all maintenance instructions had been assigned to a cognizant engineer to establish a ;
contact for comments on the procedure and to establish accountability for the adequacy of the procedure No violations or deviations were identifie . Review of Corrective Maintenance Procedures (62700)
The inspectors reviewed administrative requirements and maintenance procedures to evaluate the adequacy of the licensee's implementation of .
maintenance programs used to upgrade maintenance p'rocedures including the !
Maintenance Instruction Enhancement Program (MIEP). The MIEP determined which procedures would be required for Unit 2 restart and prioritized these procedures in each section by the use of a priority assignment work sheet. The licensee intends to rewrite maintenance instructions in accordance with the writers guide as outlined in- current admir .strative procedure as discussed in SNPP section II. The schedule being proposed for procedure upgrade is to rewrite all high priority procedures within 8 months after Unit 2 restart and to rewrite all other required maintenance procedures within 21 months after Unit 2 startu In order to evaluate the adequacy of the procedures currently in place, the inspectors obtained a copy of the licensee's listing of procedures required for Unit 2 startup. The list included those procedures which had completed a review based on the following criterion:
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Corrections of documented deficiencies or weaknesses in existing site procedures identified and documented by NRC; industry
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organizations; and internal audits, inspections, reviews, or investigation Procedure revisions required to incorporate completed plant modifications or as the result.of system walkdown Procedure revisions required to reflect changes due to reorganizatio '
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Procedure revisions required to implement other programmatic .
improvements called for in the Nuclear Performance' Plan and required prior to startup; or required by the NQA The inspectors selected maintenance procedures in the. mechanical, electrical, and instrument maintenance areas which had been reviewed based on the criterion listed above to determine if the instructions are essentially technically correct and adequate for strrtu The review also included a detailed evaluation'of implementation of the SNPP, Re ,Section II, paragraph 4, Maintenanc . . . . . - .
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l Prior to conducting the procedure review the inspectors reviewed the administrative procedures which control maintenance activities at the j plan Specific administrative instructions reviewed:were:
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Standard Practice SQM-1, Sequoyah Nuclear Plant Maintenance Program, Rev. 1 Standard. Practice SQM-2, Maintenance Management System, Rev. 2 The inspectors concluded, based on review of the preceding administrative instructions, that the licensee has revised SQM-l'to include a procedure writer's guide which is required to be used for writing.of new 4 maintenance procedure The revised instructions provide for upgrade of ) '
all maintenance procedures to the extent that checklists and craft review will be incorporated allowing for a more complete product that will minimize probability of an inadequate procedure or incorrect performance ;
of work. -The inspector's also noted that SQM-2 provided instructions to '
the craft performing work to conduct a pre-job review of all CSSC work j packages prior to starting the work in order to evaluate adequacy of.the
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instructions. Also, if supplied instructions are inadequate, the craft 3 is required to stop work until appropriate corrections are made to the l instruction After review of administrative requirements, the_following Maintenance '
Instructions (MI) were reviewed for technical adequacy:
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MI-4.1, Rev. 3, Repacking of Pressurizer Spray Valves I
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MI-6.9, Rev 6, Safety Injection Pump' Inspection
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MI-6.20, Rev. 6, Lifted Cables
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MI-10.4, Rev. 10, 6900V Vital Switchgear Inspection
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MI-10.5.1, Rev. 2, Boric Acid Transfer Pump i
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MI-10.13, Rev. 10, Ground Detection on Vital Battery Boards j
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MI-10.20, Rev. 10, 6600 and 460 Volt Motor and other Electrical Devices Insulation Resistance Tests
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MI-10.34, Rev. O, Main Control Room (MCR) Lighting j l
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MI-10.38, Rev. 1, ASCO Solenoid Valves I l
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MI-10.39, Rev. 1, Electrical Testing of Diesel Generator Excitation System Saturable Transformers
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MI-11.3, Rev. O, Removal of Threaded Cover Assembly of Rockwell Check Valves Waich Have Become Seized L
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MI-11.7,.Rev. 5, Base Metal Weld Repair of Carbon Steel Castings, Forgings or Metal Plates )
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MI-15.2.1, Rev. 4, Lubrication of Reliance Motors
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MI-15.3, Rev. 1, Maintenance Inspection and Repair of Kerotest Manual "Y" Globe Valves
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MI-15.6.1, Rev 2, Lubrication of Westinghouse Motors
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MI-6.5A,' Rev. 9, Plugging Containment Spray Heat Exchanger Leaks
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MI-6.8, Rev. 4, Containment Spray Pump Inspection
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IMI-92-FDM-CAL, Rev. 3, Nuclear Instrumentation System Flux Deviation (Current Comparator)
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IMI-94, Rev. 4, Movable Incore Detector
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IMI-99 CC 6.13A, Rev. 3, Channel Calibration of Loop 1 Reactor Coolant Flow Channel 1 (Loop F-414)(F-68-6A)
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IMI-99 CC 11.52A, Rev. 7, Online/Offline Channel Calibration of Delta T/TAVG Channel I, Rack 2 (T-68-2)
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IMI-99 CC 16.68, Rev. 10, Channel Calibration of Containment Pressure Channel II, (P-30-44) (P-936)
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IMI-99 FT 5.1, Rev. 5, Functional Test of Pressurizer Level Channel I I, Rack 1 Loop L-68-339 (L-459) l
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IMI-99-FT-7.10, Rev. 7, Functional Test of Steam Generator Level Loop Channel IV, Rack 12 (L-547) (L-3-110)
The reviews included a field walkdown or tabletop walkdown of the instruction with the cognizant technician and included a comparison to vendor manual requirements, plant drawings, and appropriate reference documents. Also, a checklist was used by the inspectors to insure continuity of the reviews The following is a listing of discrepancies !
found during this review:
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MI-4 1 The review determined that the procedure was technically i adequate; however, the procedure did not indicate when the post ';
maintenance test would be performed after maintenance was completed (Paragraph 6.0) .The licensee provided the ins.< ; tor with a copy of ,
a work package which repacked a spray valve in 1984. In that I package the retest was accomplished by SI-146 at normal operating pressure (N0P). The inspector considers that this retest was adequate; however, recommends that the maintenance instruction could
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29 be enhanced by stating that the packing leak test should be performed at NOP.
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MI-6.5A The review determined that the procedure was technically I adequate; however, the inspector noted that following the welding of tube plugs, the welds are inspected by a dye penetrant test (PT).
In this instance, the procedure provides no referencing of PT procedures, hold points or documentation for this inspection. The licensee indicated that procedures for the PT are specified by the work request.
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MI-6.9 The review determined that the procedure provided for adequate instructions to inspect the pump except for step 5.16. In that step the top case half is reinstalled; however,.the requirement to install a gasket is not specifie The inspector reviewed the-work package which performed the last inspection and determined that no additional instructions were provided to install a~ gasket; however, considers that the work was performed correctly due to the satisfactory performance of the post maintenance operational test which would have indicated if the gasket had not been replaced. The inspector noted that the technical manual did not specify installation of a gasket although a gasket was required. Also, the post maintenance test identified in the instruction (paragraph E of Appendix B) did not require inspection of mechanical joints pump casing for leakage during the test. The licensee stated that observation of a component for leakage of mechanical joints during operation is a normal practic MI-10.4 The procedure did not have a current revision to a technical manual listed in the procedure. The technical manual revision had been received in document control in February, 1987; however, at the time this procedure was being reviewed by the inspector, June 19, 1987, this correction had not been made nor had the punch list to the procedure been updated to indicate-that a new revision was applicable. The licensee provided a copy of the administrative instruction, AI-23, Rev. 25, Vendor Manual Control, which required site sections to ensure that any vendor requirements that must be followed are incorporated or documented into plant procedure as appropriate (paragraph 7.1.C). The engineer' stated to the inspector that he had reviewed the new revision against current l procedure requirements and determined that no changes were require c I
The inspector concluded that the procedure was adequate; however, considers that the time period between receipt of the new revision f in document control and incorporation of the new revision into the )
procedure or the procedure punch list.to be excessive. The licensee then provided the inspector with a draft change to AI-23 which would require section implementation of revisions to technical manuals '
within a specified timefram As discussed in paragraph 7 of this report, the revised procedure was reviewed. The inspector considered that this change resolved the issu _-------_--_____-.)
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MI-10.34 The procedure as written does not meet the stated objective There was no statement allowing separate sections of the procedure to be performed at different times; however, all sections are not. required to be performed for all occasions. This ,
procedure was issued in 1984 and has never been performed even -l though it has a periodicity of six months and was a refueling cycle requiremen Subsequent to this review, the licensee evaluated the procedure and e determined that PMs 0962-247, 1626-247, 1627-247,1628-247, and f 1663-247 contained the same requirements that this procedure I addressed and cancelled MI 10.3 l
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MI-10.38 The procedure in itself was technically inadequate. The procedure disconnected a solenoid coil in a NOTE, but never had the coil reconnected. The coil needed to be disconnected for other ,
sections due to removing the valve from the line, however there were !
no instructions to do s Likewise, there were no instructions to ]~
reconnect the coil after maintenance prior to testing the solenoid valve. The procedure had omitted sign-offs for the torquing of valve disc guide caps by the performer and also for the QC verification. Action steps were placed in the Precautions section as well as in several Notes. The statement in the Precautions section also had a sign-off and independent verification required on the Data Shee Review of work packages utilizing this procedure to date revealed that the procedure had never been required to be implemented in its
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entirety. The method of implementation for previous work performed had not required any of the inadequate sections to be performed, only specific sections such as those for torquing requirement The i work package did compensate for the inadequate procedure by detailed I instructions supplied by the maintenance planne The inspector was {
later provided a copy of change 87-941, which corrected these )
error *
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MI-11.7 The review determined that the procedure was technically adequate; however, the applicable codes had not been identified in the reference section. Also there was no instruction for the cognizant engineer to research codes and regulatory requirements to ensure that all requirements have been considered before l implementing the procedure. The inspector reviewed copies of three work packages generated during 1982, 1984 and 198 No discrepancies were identifie MI-15-.2.1 The inspector reviewed the instruction and determined that the motor was not required to be run after final reassembl The procedure was technically inadequate in that it did not have an adequate post maintenance test to demonstrate that mechanical interference was not a proble The inspector requested that the licensee review some past performances to determine if additional retest instructions had been added to the work packag The
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licensee reviewed several past' performances and determined that no -
additional retest was required.. The licensee promptly corrected the procedure via instruction.. change number 87-923 and stated that the fans would be retested to assure operabilit MI-15.6.2 The inspector reviewed the instruction and determined that the motor was not required to be run after. final reassembl The procedure was' technically inadequate in that it did not have an adequate post maintenance test to demonstrate that mechanical interference was not a problem. .The licensee subsequently issued instruction _ change 87-925 to correct the inadequacy in this procedure and indicated.that the fans would be tested to assure operability. The inspector was also provided a copy.of change 87-924, indicating that a similar procedure, MI-15.4.1, Lubrication of Allis Chalmers / Siemans Allis Motors, had been revise IMI-92-FDM-CAL This procedure was lacking independent verification for the replacement of plugs and for the manipulation of. switche The Post Maintenance Testing section was ambiguous in that it stated that " appropriate calibration"_would be performe IMI-94 This procedure was missing the Reference section entirel It was also missing the data sheet with' sign-offs for Section IMI-99 CC 16.6B. No discrepancies were noted with the procedur This procedure was observed during performance of the Rack Calibration section. No discrepancies were noted during this observation-.
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These noted procedural discrepancies indicate that some maintenance activities which are required for startup, may be_ conducted in an inadequate manner. When used in conjunction with other administrative control mechanisms such as work request packages, the' inspectors' observed that, in general, additional instructions for performance of the maintenanc which compensated for these discrepancies were added. .In regard to the l findings on inadequate post-maintenance testing of fan motors,-(MI-15.2.1 l and 15.6.1), these procedures had not.been performed since the enhanced training on post-maintenance testing and the issuance of-SQM-66 had been completed. These corrective measures should have'provided additional requirements that would have' precluded future inadequate testin In light of the corrective actions taken to assure-adequate maintenance by assuring that work request packages provide appropriate instructions for maintenance, and Neognizing the craft review-requirements and the management directive to stop work if-deficiencies are identified-in maintenance procedure during performance', the NRC staff believes that it is more beneficial to pursue the comprehensive review of these procedures as described in the licensee's Maintenance Instruction Enhancement Program which will correct both the' technical'and useability problems
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promptly rather than expend manpower in a' brief technical adequacy review l in the short ter As previously stated in paragraph 5 of this report, the licensee committed to provide a submittal to the NRC, by August 14, 1987, which describes the Maintenance Instruction Enhancement Program including:
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a commitment to finalize the writer's guide to assure that consistent guidance is utilized throughout the enhancement effort,
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details of the scheduling of the plan, l - firm commitment dates for completion of the enhancement of the maintenance instructions, and
, - the validation and verification program for enhanced procedures.
The NRC staff will review this submittal during the restart readiness inspection, and determine if the long term plan represents an acceptable ,
method to control the resolution of procedural deficiencies to allow '
restart of the unit No violation or Ceviations were identifie . Preventive Maintenance (62700)
The inspector performed an in-depth programmatic review of the licensee's preventive maintenance program that consisted of interviews with responsible personnel, review of controlling procedures, and analysis of the mechanisms used for accountability and feedbac The previous inspection in this area, NRC Inspection Report 327, 328/87-15, noted that the NMRG had identified specific weaknesses in the preventive maintenance program, but the licensee had not completed implementation of improvements recommended by the NMRG to correct the identified weaknesses. The inspector determined during the current inspection that the licensee has made significant progress towards the goal of establishing an effective and comprehensive preventive maintenance program. The inspector noted, however, that formal corporate direction was still in the formative stages. Overall, the present state l of the preventive maintenance prngram is adequate and meets the regulatory requirements contained in Section 5.2.7 of ANSI Standard
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N18.7-197 ,
1 Management of PM Program Responsibility for the Sequoyah oreventive maintenance program is ;
presently assigned to the Manager of Maintenance Special Projects I who reports directly to the Maintenance Superintendent. The l Preventive Maintenance Manager reports to the Maintenance Manager of 1 Special Projects and at this time is filled temporarily with the !
designated PM Manager assigned to the Watts Bar sit At present,
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the licensee is actively seeking to fill this position permanently and plans to do so by October 1987. The Manager of Special !
Maintenance Projects is at present also overseeing an upgrade of the PM program by an outside contractor. The managers implementing the '
preventive maintenance program appear to be experienced and well qualifie !
No violations or deviations were identifie b. History and Trending The Manager of Maintenance Special Projects supervises the Environmental Qualification and Trending section The Trending section reviews corrective maintenance work requests to determine ;
failure trends and, if appropriate, increases the frequency of PM performed on specific pieces of equipment. The inspector reviewed SQM-58, Rev. 6, Maintenance History and Trending, to assess whether or not this procedure was comprehensive in its scope and discretion in determining and detecting failure trends. The trending' program uses three databases for its purpose. These are the EQIS-Equipment Information System; NPRDS-Nucleae Plant Reliability Data System; and, Prime Data Base. EQIS is TVA's database for storing nameplate, j maintenance history, and other useful information on components '
utilizing their unique TVA identification numbe NPRDS is a .
program managed by INPO to provide common maintenance history and l reliability information among domestic nuclear utilitie PRIME data base is an early TVA equipment cataloguing system that is ,
useful only when a failure trend is apparent or particular component information is needed. The Prime data base does not support generic trendin SQM-58 offers guidance to the engineer evaluating trends and lists 11 questions to be answered when evaluating failure trends. The engineer first determines if preventive maintenance is being conducted and if the frequency of the PM should be increased. The following questions are all logical and, if followed, should adequately address any noted failure trend The procedure then lists the different items and their deportabilit First of these is Class 1E and 10CFR 50.49 items. Each maintenance group reviews and evaluates the generic and repetitive failures on an annual basis using the guidance given in the procedure as a minimum. . Secondly, the Performance and Analysis Section will issue a NPRDS report to the maintenance sections. This report is issued semiannually and will contain a listing of generic and repetitive failures that exceed the threshold criteria specified in the procedure. Thirdly, whenever an item or component failure causes a reactor trip, turbine trip, load reduction, or generation of a Licensee Event Report (LER), a generic and repetitive failure evaluation is required to be completed. Finally, the procedure suggests that each maintenance group obtain a report of the non-Class 1E or non-NPRDS in listed safety systems found in an attachment to the procedure. The
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I procedure contains, a.s attachments, the methods by which failure evaluations are to be conducted by the maintenance groups. All of these categories required evaluations to be performed to address the
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J noted failures. The inspector reviewed these attachments and found them as well as the rest of the procedure to satisfactorily address
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maintenance history and trendin i No violations or deviations were identifie (
c. PM Procedure Review l The licensee provided a printout.to the inspector of all PM procedures listed by responsible sections. The information listed ;
included th'e procedure number, responsible section, equipment I.D.,
foreman, whether or not the equipment is a Critical Structure, .l System or re ponent (CSSC), a brief work description, frequency, l schedule date, and due date. The inspector performed a cursory l review of the list to assure that equipment that required PM was i included. _ Among those noted were Limitorque valve operators, j reactor coolant pump motors, reactor trip breakers, 125VDC vital
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batteries, auxiliary feedwater pumps, and centrifugal charging pumps. The inspector noted that a number of PMs had been cancelled due to combining several redundant procedures into one, the coverage of a PM by a surveillance instruction, or a plant modificatio Overall, the list represented the master schedule for PMs and indicated that an adequate database for PMs existed and was being satisfactorily managed. The licensee leaves the cancelled PMs on this list because it is part of the document control lifetime record of the plan The licensee uses a second " active" PM list when reviewing PMs that are being performe The following procedures were reviewed for technical adequacy: )
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PM 0674-030, Rev. 3, Turbine Bldg. Space Coolers PM 0066-031, Rev. 3, Service Bldg. A/H & A/C Filters PM 2099-027, Rev. 1, Condenser Circulating Water Pump Motor 2B PM 0367-088, Rev. 3, Inspection / Lubrication Unit 1 Reactor Bldg Air Lock Door i
PM 1603-077, Rev. 1, Sump Tank Pump B j
PM 1750-062, Rev. 1, Boric Acid Transfer Pump 2A-A PM 1803-030, Rev. 1, Reactor Lower compartment Cooler Fan 20-B Motor PM 0712-030, Rev. O, Diesel Generator 28-B Battery Hood Exhaust PM 8110-067, Rev. O, limitorque Operator-Component Cooling Heat
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Exchanger "A" Discharge PM 1337-068, Rev. 1, #2 Reactor Coolant Pump Motor PM 1766-067,.Rev. 1, ERCW Pump Motor L-B PM 8077-001, Rev. O, Limitorque Operator-AFPT Stm Supply from S/G #1 PM 1633-043, Rev. O, RCS Hot Legs Hdr Ctmt Isolation Valve
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PM 1302-250, Rev. O, 125 Volt DC Vital Battery III PM 1193-063, Rev. O, SIS Accumulator Tank 4 Flow PM 0526-000, Rev. 6, Limitorque Operators l l
PM 1505-063, Rev. O, Safety Injection Pumps A & B PM 0324-003, Rev. O, Auxiliary Feed Pump - Turbine Driven 1A-S, 2A-S PM 8000-001, Rev. O, Limit Switch-S/G #1 Steam Header Power Relief Control Valve PM 1467-003, Rev. O, Level Inuicating Controller PM 1683-313, Rev. O, Shutdown Board Room A&B CW Pump A-A Pressure PM 1896-087, Rev. O, Accum Isol Valve Low Level Activation Switches !
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PM 1941-001, Rev. O, Steam Generator Steam Pressure Loops 2 & 3 PM 1950-074, Rev. O, RHR System Outlet Hx A & B Temperature PM 1962-063, Rev. O, System 63 Foxboro E11DM Flow Transmitters PM 1966-046, Rev. O, Aux Feed Pump Turbine Flow Indicating Controller PM 1254-068, Rev. O, RVLIS Transmitter Panel Isolation Valves I PM 1226-092, Rev. 1, NIS Drawers & Spare Power Supplies In Pwr I Stores i
PM 1239-090, Rev. O, Radiation Element PM 1894-074, Rev. O, RHR Pump Mini-Flow V1v Flow Switches PM 1685-070, Rev. O, Thermal Barrier Sply Hdr Flow PM 1680-070, Rev. O, Thermal Barrier Sply Hdr Flow I
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l PM 1350-317, Rev. O, Electrical Hipot Testing l l
The inspector reviewed the procedures against SQM-57, Rev. 8, Preventive Maintenance Program, to gauge the conformance to the ,
administrative requirements on format, approval, and contro Post l maintenance testing and QC hold points, where required, were j appropriate. Most of the PMs reviewed invoked Maintenance Instructions to perform the wor It was noted in the review of PM procedures that some of the procedures simply invoked a maintenance instruction procedure while others actually listed steps to'be performed out of a maintenance l
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13struction. One such procedure is PM 8000-001, Limit Switch-S/G#1 Stm Hdr Power Relief Control V1v, Rev. O. This procedure instructs the technician to perform steps out of MI-10.37, Limit Switch Model
- EA740. The inspector noted that if the steps were performed as j instructed, the technician would never be able to perform the task j because they would never have performed the step requiring them to j
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remove the switch from its mounting bracket and remove the bottom cover and gasket. In addition, there is no mechanism for revising PM 8000-001 whenever MI-10.37 is revised. The PM procedure should be revised to provide more explicit instructions, or it should not reference specific steps in a procedure that could be revised j without a mechanism for revising the PM procedure. The licensee had
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identified this inconsistency for the modification process in NMRG Finding E-1 and taken corrective actio In addition, the licensee issued a CAQR for the procedure revision process to assure that the procedure revision process included the review of all pertinent instruction No violations or deviations were identified.
d. Review of Work Requests Associated with PMs Inspectors reviewed completed work requests associated with the l following Preventive Ma<ntenance packages:
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i PM 8000-001, Limit Switch-S/G #1 Steam Header Power Relief Control Valve PM 1193-063, SIS Accumulator Tank 4 Flow j i
PM 0712-030, Diesel Generator 2B-B Battery Hood Exhaust !
l PM 1603-077, Sump Tank Pump B !
PM 1337-068, #2 Reactor Coolant Pump Motor PM 0367-088, Inspection / Lubrication Unit 1 Reactor Bldg Air Lock Door
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PM 0066-031, Service Bldg. A/H & A/C Filters PM 1705-078, Spent Fuel Pit Pump C-S Motor ;
PM 0126-182, D/G Battery 2A- PM 1486-003, Auxiliary Feedwater Level Control Valves PM 0857-030, Penetration. Room A Pipe Chase Coolers ]
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PM 1651-067, ERCW Pumps PM 1612-077, Waste Gas Compressor A These PM packages were also reviewed for compliance with SQM-57'Re . The inspector noted no discrepancies in the work packages reviewed No violations or deviations were identified.
e. Incorporation of Technical Specification Changes and Changes Due to Plant Modifications
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SQA-30, Rev. 3, Responsibility For Technical Specification Changes, is the procedure followed for review and approval of Technical Specification revisions. This procedure is being revised to streamline the process of TS revision Included in this revision j are provisions for the notification of the PM department by the use /
of a master equipment list that lists all procedures associated with i any equipment involved in a revision to the T The Inspector reviewed AI-19, Plant Modifications, Part IV, After Licensing, Rev. 22, approved May 22, 1987. This revision added to the procedure the action to notify the PM department if a review needed to be conducted of the modification for its impcet on present PM, or if it required a new P The inspector finds this revision to acceptably address this ite No violations or deviations were identified, j i
f. Corporate Involvement in PM Program The inspector noted that the corporate organization had yet to provide definitive direction to the PM progra The corporate directive had not been issued, but the inspector was provided with a draft of the directive. The inspector reviewed this draft directive i and found the directive to be a good stanoard for structuring the PM j program. The draft addressed many of the NMRG findings and endorsed :
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the establishment of an automated maintenance management computer database system. Of particular interest was the section on i Predictive Maintenance. The inspector reviewed the licensee's !
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predictive maintenance program during the March 2-6, 1987 inspection and had determined that the program was adequate and somewhat unique in the industry in that many state of the art methods for predictive maintenance were being developed for the progra Thedirectije lists a number of predictive maintenance techniques to be considered ;
for implementation. The inspector cons;uers that the implementation l of these features would greatly enhance the licensee's ability to provide early. indication of equipment failures that cause a majority ,
of unplanned trips. Performance indicators for the PM program are !
also addressed as a part of the draft directive. A review of the final corporate directive for the PM program will be conducted at a later date, j No violations or deviations were identifie . Development of Long Term Enhancement Program 'l i
The inspector reviewed a draft contract being drawn up for a l contractor to assist in the enhancement of the PM program. Included 1 in this contract is the identification of PMs, selection and prioritization of PMs, review of vendor manuals (already being i conducted in response to Generic Letter 83-28), operating experience !
review, predictive maintenance, work planning, instruction j preparation, and PM aeviation justification. The content of the j contract along with the content of the draft direc':ive indicate a 1 strong commitment to upgrade the PM progra '
No violations or deviations were identifie . Review of Work Packages and Observations of Maintenance Activities
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(62700)
The inspectors reviewed a number of completed work packages and work packages that had been planned but not disseminated to the crafts for work. The inspector reviewed the work package to ensure that the .
procedures specified in the work package were adequate for the '
maintenance performed, that the post maintenance testing-specified on the work request was adequate for the work performed and that the work package met the requirements of SQM-2, Maintenance Management System, Rev 24. All tt3 work packages reviewed appeared adequate to perform the l maintenance activity specified and perform adequate post maintenance test The inspe: tors reviewed work in progress in accordance with maintenance work requists (WRs), preventive maintenance (PM)' requests and work plans (WPs). The following instances of failure to follow procedure were identified. Although the individual cases identified have minor safety significance, these findings indicate that maintenance procedures are being interpreted by craftsman incorrectly in some case Mechanics interviewed who were involved in the work observed indicated that they believed that the practices were allowed under the procedures.
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i WR B297733 The inspector observed repacking of valve 2-VLV-070-680 in 4 accordance with MI-11.4, Rev. 19. The inspector determined that {
paragraphs 6.10.9.2 and 6.10.9.3 of MI-11.4 were not performed during the j repacking. These steps require that measurements be taken to verify the l packing dimensions are within 1/64 inch of the stuffing box dimensions, j The mechanics interviewed stated that the method used, to verify that the packing was the. appropriate size, was to compare the packing ring to the f old packing removed and to observe the fit of the new packing in the i stuffing box by visual verification of the dimension The licensee stated that the procedure was written to require that actual measurements of the stuffing box spacing and the. packing be taken. Failure to perform steps 6.10.9.2 and 6.10.9.3 is a failure to follow procedure MI-11.4 and is an example of violation 328/87-37-01. The licensee subsequently determined that the visual veri /ication method was acceptable for precut packing and stated that the procedure would be changed to allow this metho WR B230619 The inspector observed repacking of safety injection valve !
2-VLV-63-0005. The inspector determined that paragraphs 6.10.9.2 and 6.10.9.3 of MI-11.4 were not performed during the repacking, These steps require that measurements be taken to verify the packing dimensions are within 1/64 inch of the stuffing box dimensions. Tne interview with the mechanics indicated that the visual observation method described above under WR B297733 was also used during this repacking operation. Failure to perform steps 6.10.9.2 and 6.10.9.3 is a failure to follow procedure MI-11.4 and is an example of violation 328/87-37-0 In addition, the inspector observed the mechanic apply a lubricant to the l valve ste Section 6,9 of MI-11.4 requires that a QC in'spector verify i the lubricant type prior to applicatio Step 6.9.1 states that valve stems may be lubricated as necessary and that the determination of need for lubrication shall be made by the planner, craftsman, or cognizant engineer. Step 6.9.2 states that if stem lubrication is required that i the system design temperature shall be determined and that a QC inspectcr shall verify the lubricant type and complete a data sheet. Step 6. also requires that graphite / isopropanol be used for systems with design temperatures greater than 150 F and that Never-Seez or equal shall be used for all other systems. WR B230619 did not specify that lubricant was to be applied to the valve stem and, therefore, the lubricant type ,
was not verified by QC. The mechanics interviewed stated that they did l not consider the application of the lubricant to be valve stem lubrication but rather that it was the lubricant was used to ease the insertion of the packing. The mechanics also stated that application of the lubricant to the stem and application of Never-Seez to the packing was a common repacking operation. The mechanics stated that the materials issue form was reviewed to assure that the appropriate lubricant was applied and that the mechanics considered that the lubricant was QC verified under the materials issue form, Failure to follow WR B230619 is an example of violation 328/87-37-01. The licensee determined that the lubricant used in this case was Neolube, which was the appropriate lubricant for valve 2-FCV-63-0005.
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The following maintenance activities were observed with no deficiencies identified:
WR B209524 The inspector observed the inspection of the EL 669 28-B pipe chase cooler for degradation. During the observation, the inspector questioned the Health Physics practices employed when the system was opened. The licensee provided the smear data for the cooler, which indicated that the area was well below the levels for establishing a contamination zone. The licensee also provided a copy of Radiation Work Permit (RWP) 87-0014-003. 'This RWP had been listed on the work request as the appropriate RWP for use when the cooler was cleaned. This RWP '
appeared adequate for the work to be done. The inspector had no further I question I WR B229310 The inspector observed removal of bearing and installation of missing retaining ring on RHR pump 1B-B. The inspectors discussed the licensee's evaluation of the 18-B RHR pump with a licensee representative. The pump failed a surveillance test on high discharge pressure. The licensee visually inspected the upper thrust bearing and did not note any problems. The engineers rotated the shaft and discovered that the shaft did not move freely at one point in the tur The pump was disassemble During the subsequent review which included measurement of various component clearances and comparison of internals to drawings and vendor manuals, the licensee determined that the pump did not have a retaining ring for the upper thrust bearing as shown in the
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drawings. A retaining ring was obtained from a spare motor and installed. The licensee is investigating the reason for the missing retaining rin In addition, the replacement retaining ring was nonconformed due to galling at the bolt / ring interface. The licensee performed a metallurgical examination of the ring and determined that the retaining ring was acceptable for use and the nonconforming condition report was cleared. The licensee also determined that shims had been J placed at the interface between the motor and motor stand. The vendor I recommended removal of the shi The vendor provided guidance to f readjust the lower guide bearing to allow the appropriate clearances for thermal growth. The licensee's initial indication was that clearances at the interface between the motor and motor stand were excess 4ve allowing slight cocking of the shaft. During reassembly, the motor was centered on the stand. The licensee believes that this will correct the alignment problem. After reassembly, the licensee observed leakage at the pump shaft. PMT was delayed to evaluate this problem. The licensee has reviewed the problems with respect to pump operability and determined that the problems had not affected pump operability and'were not reportable. The licensee is continuing the investigation and will examine the other Unit 1 and Unit 2 RHR pumps for similar problem Follow-u~p on the discrepancies is being tracked by .the licensee via CAQRs i SQP871253 and SQP871252. The NRC Resident Inspectors are following the I
licensee's additional corrective action WRs B228030, B228879, B228882, B228032 The inspector observed the performance of electrical high potential testing of class IE 6900 volt
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power cables associated with ERCW pump The testing was required to verify integrity of cables associated with Employee Concern Task Group Report 304.03 SQNR1. This concern identified possible degraded cable life due to moisture buildup present in the electrical manways that the cables were routed. A DC Hipot Tester was utilized for testing as allowed by MI-10.20 for 6900 volt service.
WRs 8228888,'B228887 The inspector observed the performance of megger testing per MI-10.20 of 480 Volt Diesel Generator Boards IAl-A and 281-B.
WR B276251 The inspertor observed electrical troubleshooting associated with failure of the 1A1 Emergency Diesel Generator during surveillance testing. The Diesel Generator tripped during performance of SI-26.1.
The overcurrent, ground fault, and ground differential flags were present on the generator output breaker following the trip. Troubleshooting revealed the failure was due to grounding of the B phase saturable transformer, T52, for the generator voltage control. Further testing showed the other two phase's saturable transformers, T51 & T53, to require replacement due to excess electrical leakage. The components were replaced and high potential testing was performed in accordance with MI-10.39 on the replaced parts and the associated electrical cables up to the associated shutdown boar Additional identified post maintenance testing included performance of SI-7, Diesel Generator Operability.
WR B129660 The inspector observed torquing of pipe support clamp bolting and staking of valve stem for hanger 2-SHK-001-MSH-314 in accordance with SMI-0-317-39.
WR B211695 The inspector observed replacement of gear box gasket on l valve 2-MOV-070-134B in accordance with procedure MI-11.2A, Rev. 2, !
Limitorque Actuators Corrective Maintenance Procedure for SB-00, SMB-000, and SMB-00 Actuators.
WR B211695 The inspector observed MOVATS test on valve 2-MOV-070-134B in accordance with procedure MI-10.43, Rev. 5, Procedure For Testing Motor Operated Valves Using MOVATS System.
The inspector observed monthly PM of Diesel Generators 2BB-1 and 2BB-2 in accordance with procedure MI-4.2.3, Rev. O, Monthly Preventive i'
Maintenance of Diesel Engines.
WR B236808 The inspector observed replacement of Diesel Generators 2BB-1 and 2BB-2 Bearing Box site Glasses.
WP 12515 The inspectors observed the fielci calibration of I/P converters for Auxiliary Feedwater Level Control Valve Bypass Valve I&C technicians were only able to calibrate one of two I/P converters and were planning to either re perform the bench calibration or replace the defective I/P converter.
WR B222584 The inspectors observed the replacement of a diaphragm on a
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leaking Auxiliary Feedwater Level Control Valve 2-LCV-03-0173 in accordance with procedure MI-11.4, Rev. 19, Maintenance of CSSC Valve The valve was found leaking while performing step 6.57 of SI-15 Appendix WR B215778/1106 The inspector observed lapping of the valve seat fo containment isolation check valve 2-VLV-070-69 WR B222343 The inspector observed the seal weld of a spare PORV including the check of weld filler material and the liquid penetrant inspection of the seal weld.
l WR B125591 The inspector observed portions of the rebuild of.the Bettis L actuator on the Unit 2 lower compartment purge isolation valv PORV Replacement / Rework The inspector reviewed work associated with reworking the Unit 2 Pressurizer Power Operated Relief Valves (PORV) to correct problems with slow stroke timing. This work was the highest priority job occurring during the inspection period and involved extensive planning and coordination effort prior to the start of the jo The maintenance involved work under different disciplines covered by various WRs. Much of the work was done directly by or under the direction of a factory representative from Target Rock Inc. Additioncily the work was closely followed by the cognizant engineer to preclude any problem !
l The inspector monitored a prework briefing held by the cognizant engineer with personnel from all related disciplines attending. The meeting ,
appeared to be successful and valuable information was exchanged "
concerning scope of the work, HP requirements, effects on technical ;
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specifications with one PORV out of service, availability of the vendor representative onsite, problems associated with extreme work environment (local temperature & humidity required short initial stay times), et l
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WR B222345 The inspector observed electrical troubleshooting of PORV control circuits. When no problems were revealed, the PORV was electrically disconnected and the solenoid assembly removed to allow the *
valve to be removed and taken to the valve shop for. mechanical rebuilding of the valv WR B248159 The WR was originally written to remove and replace valv .
The valve was removed but a clean spare PORV (S/N #9) was later installed as a replacement when a crack was found in seat of original PORV and the contaminated spare PCRV required additional seat work before it could be use WR B295269 The clean spare PORV was taken from storage and stroke tested with a portable Target Rock Power Supply. During the stroking a boroscope was used by the vendor representative to perform visual
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inspection to verify the position of the valve seat' spanner. holes in _ -l relation to the flow path in accordance with vendor requirements. The valve assembly was then leak tested in the shop in accordance'with a special test written as part of the W j l
WR B222343 The original PORV was removed from the system under WR B24815 The valve seat was discovered to be cracked. The WR was then j replan _ned to call for heating the valve body to approximately 600-degrees I F, (not to exceed 800 degrees F), to remove the sleeve from valve body,-
install a new sleeve, and replace the pilot disc and-piston-rings. The licensee then intended to' place the valve in spares. The PMT specified performing a leak check in the shop in lieu of SI-158.1 and the per,nrmance of SI-166.6, Valve Stroking, if later placed in system '
The inspectors'reviewea the backlog of maintenance requests. The 1
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licensee had previously identified maintenance requests that were required for startup. This process was reviewed by.the'NRC and sel_ected MRs were reviewed to assure that the .startup designation was appropriate as documented in NRC Inspection Report 327, 328/86-18. The_following information is for Unit 2 and. Unit 0 as of July 24, 1987. :The licensee j indicated that 337 MRs had been identified for completion prior to-startup In addition the licensee has 68 MRs'affecting the control room, 145 MRs to correct tagging deficiencies identified during walkdowns, 2270 ]
CSSC MRs other then those in previous categories and 1130 MRs in non-CSSC l systems. The total MRs outstanding for Unit:2 and Unit 0, excluding:the non-CSSC MRs, are approximately 2800. At the end of this inspection (July 31), the licensee indicated that the total had been reduced to j approximately 2600. The licensee's goal for restart is approximately I
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1500 MR . Planning and Scheduling (62702) ]
The inspector reviewed the work planning and scheduling process. To'
improve performance in the planning and scheduling function the licensee increased the manning levels in the planning section. The licensee has also assigned three senior reactor operators (SR0s) to the planning section and developed a long term training program for maintenance planners. The assignment of SR0s was implemented to assist in effective i interface with operations and to improve expertise in the planning of post-maintenance testin ;
The long term training program has been defined; however, the program has !
not yet been implemented. The licensee has:provided training to the planners on SQM-2 and on post maintenance testing. During this J inspection, the licensee conducted an 8-hour _ class on post maintenance-testing for planner The inspector attended 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the training a.1d reviewed the training materials provided. The training provided appeared '
to be useful to the planners present and provided examples and guidance on what type of post maintenance testing would be adequate in specific ,
instance *
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Th9 licensee has revised SQMM to provide guidance to the planners on '
post maintenance testgaquirements. The licensee had also developed Post Maintenance Testing, to provide guidelines for procedureSqM-M4'testingrequiredtoverifythattheequipmentoperates post maintE$4DCe l correctly anW performs the desired function. This' procedure was issued on July 28, 1987. The procedure is structured to provide suggested PMTs l for various types of equipment. SQM-66 also contains provisions to l compile and include as references PMTs for specific p eces of equipment '
as the PMTs are developed for specific maintenance activities in accordance with SQM-6 The licensee stated that training on the s implementation of the procedure is required within ten days of issuanc ]
,d ' Itplanning is the. inspector's opinion that the licensee's actions in..the area of and scheduling and post maintenance testing are adequate to
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'h No violations or deviations were identifie i l
1 Training (62700)
An inspector reviewed the licensee's program for maintenance training of l craft personnel. The mechanical and electrical maintenance training 1 programs had received INPO accreditation on April 30, 1987, while the l Instrumentation Maintenance training program had been accredited on g.lanuary 11, 198 ,
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The program was described in separate Maintenance Section Instruction Letters for each section. MMSL-A65, Rev. 2, describes the training program for the mechanical maintenance section while EMSL-A67, Rev. 2, !
covers the electrical maintenance section, and IMS-A2, Rev. 4, covers the '
instrumentation maintenance sectio Prior to assignment to a particular maintenance secdion each craftsman
! must first undergo the normal General Employee Training (GET) and HP Training. The craftsman is then assigned to one of the sections for further training.
, Electrical and Mechanical-Maintenance Training
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For personnel assigned to the electrical or' mechanical maintenance l sections each individual is scheduled to receive initial training l during the first 3-4 months following assignment. On-the-job training (0JT) is conducted in conjunction with and/or following initial trainin Initial training consists of formal training conducted at the Power Operations Training Center and consists of the following:
l Systems Course (2 weeks)
l Procedures Training (2 days)-
Required Reading list (done at self pace by employee)
OJT is a structured program which identifies various training tasks
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that an individual should learn for a particular work assignmen Provisions are made for evaluation of the individuals performance of 4 those tasks and is documented on the OJT Qualification Card. A )
Qualification Wavier Form is used to exempt an individual based on j previous education, training and/or experience related to specific j tasks being worke These two maintenance sections utilize a task matrix which serves as a management tool to track the various task requirements for each craft worker in each duty area , e.g., refueling, diesel generators, ]
et Completion of associated sections of each qualification card is denoted by an X in the respective block on the task matrix. This matrix is then used as a method of controlling work assignment Each of the three section instruction letters contain the iaquirement that the cognizant plant maintenance supervisor evaluate individuals to ensure that they are not allowed to work independently or to be assigned lead responsibil'ity requiring that particular skill or knowledg Instrumentation Maintenance Training The training program for the !. instrumentation Maintenance personnel l
is somewhat different from that of the other two section New
! personnel first undergo a 18 month instrument mecnanic I l apprenticeship training program prior to being placed in the plan This is then followed by 2 years of in plant work performed under ,
the direction of a journeyman instrument mechanic. This comprises a i total of 7000 hours0.081 days <br />1.944 hours <br />0.0116 weeks <br />0.00266 months <br /> of formal training and OJT. All identified I required tasks must be covered during this period either by formal training or actual performance of the tas Upon successful i completion of the program the individual is certified as a l journeyman qualified to work independentl ;
All journeyman instrumentation mechanics are then required to participate in a continuing training program. This program consists
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i of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of training conducted every 2 years and includes systems and procedure training along with any identified special training ,
need No violations or deviations were identifie . Motor Operated Valve Maintenance Program (62700, 62702) i l The SNPP describes, in Section 4.3.3.a, the motor operated valve (MOV)
maintenance program. Section 4.3.3 states that a comprehensive
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safety-related MOV program for visual inspection, lubrication and testing was under development, Motor-Operated Valve Analysis and Testing System (MOVATS) equipment had been purchased, Sequoyah engineers have been trained in its use, and'a' history data base for each valve was being develope The SNPP also states that a composite crew has been established to perform maintenance on MOVs. The inspector reviewed the
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status of this progra The licensee has completed initial MOVATS testing on all valve Thirteen valves, both CSSC and balance of plant, will be., tested again after resolution of problems identified during: testing or after modifications to the valves'are completed. Preventive maintenance instructions for MOVs are in the planning stag Preventive maintenance ,'
including a visual inspection, a lubrication inspection and MOVATS testing is scheduled for completion on Unit'2 valves during the Cycle 3 refueling outag A formalized training program for personnel using the MOVATS system has been implemented. The 1.icensee is currently.using the vendor.'s training program but is in the process of developing their own training program which will be utilized following accreditatio Training of maintenance personnel W forming PMs'on MOVs appeared to be sound. Maintenance personnel including foremen are required to take' training and. demonstrate proficiency in the tasks require The inspector reviewed the division of maintenance craft into crews and determined that e composite crew had been assigned to work on MOV The crew consistad of a foreman, an engineer, four electricians, and two machinists uetailed-to the electrical maintenance sectio ,
l The licensee is proceeding with MOV testing ar,1 development of a data base including MOVATS for each safety-related valve. M0 VATS signatures have been obtained and are on file for those valves teste No violations or deviations were identifie . Nuclear Experience Review (NER) (62702) .
The inspector reviewed the licensee's NER program by reviewing the )
tracking system and assessing the adequacy of the responses to selected ' 1 IE Information Notices (IENs). The inspector chose the-following IENs i for review: i
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84-42, Equipment Availability for Conditions During Outages Not Covered by Technical Specifications ,
j 84-58, Inadvertent Defeat of' Safety Function Caused by Human Error l Involving Wrong Unit, Wrong Train,'or Wrong System 85-02, Improper Installation and Testing of Differential Pressure, '
Transmitter , Failure of Limitorque Motor Opersted ~ Valves Resulting From Inccrrect Installation of. Pinion Gear 85-23, Inadequate Surveillance and Post-maintenance System Testing 'I
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l 85-75, Improperly Installed Instrumentation, . Inadequate Quality Control and Inadequate Post-modification Testing 85-94, Potential for Loss of Minimum Flow Paths Leading to ECCS l P mp Damage During a LOCA-The inspector reviewed routing sheets, memos and responses. Tne j inspector noted that NERs in this time frame had not been formalized and 1 i
tracked with a.well defined program; however, all of the IENs except one I had been addressed. The licensee could not produce documentation that
IEW 84-58 had been reviewed. The inspector brought this to the attention .
l of the licensee and-determined during subsequent inspections that the IEN 1 had been entered into the present system. The inspector audited all IENs from IEN 86-01 to the present to assure that the present tracking system, described below, is comprehensive and addresses all IENs. The inspector.noted that all notices had been addressed, however, approximately 20% had been closed beyond the internally assigned due
_date. The licensee has established a quarterly tracking system to ' assure
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that responsible sections are aware of due dates and overdue report The inspector found that twelve files were not in the' hard copy fil Most of these files were recent IEN's but five were from 1986'. the-licensee stated that the files were under review or in transit and was i able to provide the dispositions of the notices on the NER tracking
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l The licensee currently formally reviews nuclear experience items under .
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procedure SQA-26, Rev. 11, Review, Impicmentation, and Reporting of l Nuclear Experience Review Information. This procedure establishes and
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j controls the review of the following d^cuments: j 1 :
INPO Significant Event Reports, j INPO Operations and Maintenance Reminders, INP0 Operating Experience Reports, INPO Significant Operating Experience Reports, !
Internal and external 10 CFR 21 reports,
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NRC IENs, NRC exit meeting minutes, inspection reports or violations, Written reports from NSSS vendors containing primary 'information'
including Westinghouse Tech Bulletins, General Electric Service ,
Information Letters, etc.., '
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TVA Licensee Event reports and Technical Specification'Special Reports,
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-_ NRC periodic reports, NUREG/CR-2000, NUREG/CR-0051, and NUREG-0040, INPO Good Practice The procedure is clear and makes good use of f Ww charts to aid in the dissemination and organization of NERs. Items are screened and assigned responsibility for their dispositio A NER Evaluation Form adequately covered all areas of review and required explanations for why action was d not necessary on the item or if action needed to be taken, what the action was and its possible effects on the FSAR, 10CFR 50.49 program, and ,
regulatory licensing. A NER implementation form covered many of the same areas and assigned responsibility for evaluations and actions taken. In addition, the procedure also covers in-house experience in the same manner as other NER The Regulatory Licensing Section generates an NER status report on a quarterly basi The administrative controls for the NER program appeared to be satisfactor No violations or deviations were identifie . Evaluation of Corrective Action for Nuclear Manager Review Group (NMRG)
Findings (62700, 62702)
l The licensee has conducted the comprehensive review of cor ective and j preventive maintenance at Browns Ferry, Sequoyah, and Watts Bar described ir. SNPP section 4.0. This review was conducted by the licensee's Nuclear Manager's Review Group (NMRG). The final report was issued on December 17, 1986. As stated in NRC Inspection Report 327, 328/87-15, the staff has reviewed the scope and findings of this study. The staff believes that the NMRG study was a comprehensive evaluation of the 'l maintenance programs at the TVA sites and corporate offices. The !
performance areas reviewed were based on those identified in the Institute of Nuclear Power Operations (INPO) Guidelines for the Content of Maintenance at Nuclear Power Stations. The report includes competent programmatic reviews and field observations of maintenance activities, i The staff notu that the findings of the NMRG study closely paralleled those findings identified by NRC inspection The NMRG study stated that the most significant improvement areas needed included the aggressive correction and prevention of hardware problems, corporate involvement in nuclear maintenance, and implementation of challenging goals and objectives for maintenance. The finding on correction and prevention of hardware problems cites the diffusion of responsibility for maintenance controls and checks, the lack of aggressive and coordinated efforts to soive problems and a lack of clear accountability for solving specific problem Specific findings of the NMRG included deficiencies in corporate involvement in the maintenance program, inadequate training and qualifications of planners, preventive maintenance program deficiencies, inadequate maintenance shops and office spaces, inadequacies in maintenance instructions and the performance of instructions and work requests, deficiencies in the planning and scheduling of maintenance, inadequate testing, problems with materials
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suitability, inadequate control of maintenance activities, failure to i provide adequate post maintenarae testing, problems with materials !
suitability, inadequate control of maintenance tools and equipment, lack l of management involvement in ongoing maintenance activities, incomplete 1 maintenance history programs and. failure to use trending techniques to guide maintenance, ineffective quality assurance reviews of maintenance and lack of follow through on corrective action for maintenance deficiencie On March 31, 1987, the Plant Manager formally responded to the NMRG findings by submitting a comprehensive Corrective Action Plan to the Acting Manager of Operations Engineering Services. This response was revised on May 13, 1987 to clarify the corrective actions and update the response. The Corrective Action Plan addressed both the long term and short term plans to improve the maintenance program at Sequoyah and address the NMRG finding Corrective actions in the Plan are tracked to resolution in the Tracking and Reporting of Open Items (TROI) syste Between May 11 and May 22, 1987, the NMRG conducted a-follow-up audit of 19 of the original findings that were directly related to the startup activities at the plan The NMRG closed 11 of the 19 findings for i re .ita rt . The 8 items left open and the corrective action needed included the following:
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Finding E-1, Revision to AI-19 to ensure that the procedure contains l provisions for updating the PM program after plant modification Finding E-3, NMRG found the corrective actions for problems with waivers, extensions and deferrals of PMs to be ineffectiv Finding E-5, Completion of a listing of Technical Specification (TS)/ Final Safety Analysis Report (FSAR) requirements versus PM Finding H-1, Completion of implementation of SQEP-60, Handling of l Modifications Using Design Change Notices, to assure that modifications are completed in a timely manne Finding I-1, Completion of actions to assure adequate PMTs and ;
correct interface problems with QA reviewer '
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Finding L-4, Correct problems with segregation of defective rigging and hoisting gear, segregate large slings in the turbine building, and develop method of maintaining inventory contro Finding 0-1, Provide PMT training for QA reviewers to assure that QA j review is identifying significant weaknesses in MR revie i
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Finding 0-2, Confirm that QA rejection rates for MR review decline l as an indication that problems identified by QA are correcte l
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The NMRG re-audit emphasized that additior.2. examples of inadequate post
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maintenance testing were identified. The NMRG stated that PMT in the examples identified failed to ensure that the affected hardware was )
adequately corrected. The practice of relying on surveillance instructions as PMTs was a contributor to this problem. The NRC identified one example where procedures contained inadequate PMT as
'liscussed in paragraph 8. The licensee has implemented additional q corrective actions to preclude problems of the type discovered. These j actions, discussed in detail under Finding I-1 below and in paragraph 11, j
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included issuance of SQM-66, Post Maintenance Testing; upgraded training for maintenance planners; and issuance of additional guidance by the Plant Manager. A QA audit in this area subsequently indicated that post maintenance testing had improved. Additionally, a long term training program for planners is being developed. The inspector considers that the licensee has taken reasonable actions to address this findin The NMRG re-audit identified an interface problem between the plant j Quality Assurance (QA) organization and the maintenance planning .
organization. This problem had adversely affected the conduct of post maintenance testing (PMT) conducted at Sequoyah. The report states,
" Varying interpretations of plant documents coupled with a lack of uniform guidance and a failure to escalate problems to a higher level of ,
management for resolution has resulted in inappropriate PMT l specifications." The inspector determined that corrective actions had recently been instituted to alleviate the interface problem These measures included providing an eight hour class to both QA and maintenance planners and reviewers in order to provide a common basis for a PMT requirements. In addition, the licensee has issued SQM-66, Post Maintenance Testing, Rev. O, to provide additional guidance on the content of PMTs for specific types of equipment. Training on this :
procedure, issued on July 28, 1987, was schedule The licensee has also {
conducted management meetings between maintenance and QA and instituted a i policy of working closely together to resolve QA audit findings and assure correction to preclude future discrepancie This policy includes a one-on-one interface of QA reviewers with planners and other maintenance personnel to resolve problems. The Plant Manager also issued a memorandum to managers at the site on the requirements for' Plant Operations Review Committee (PORC) review of work requests. This policy indicates that step-by-step written instructions should be included in PORC-approved procedures rather than submitted to PORC for review in a work request. The memo also provides additional guidance on the adequacy of post maintenance testin ,
The NRC staff has audited the implementation of the corrective actions taken in response to the NMRG findings, including the re-audit. It I should be noted that the licensee's Corrective Action Plan of May 13, j 1987 addresses numerous other items identified by the licensee to improve l the maintenance program at Sequoyah. The Corrective Action Plan is :
comprehensive and. appears to carefully document each item, the planned I corrective actions, and the documents needed for closeou The. Plan )
indicates those items considered to be required for restart and those .j items to be pursued on a defined long term schedule. Tracking of these l
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items .4 completion appeared to be adequat The inspeci.rs audited the corrective actions for the following NMRG items:
Management and Corporate Invo.vement in the Maintenance Program (Restart - Closed)(Long-Term - Open) Finding A- Corporate Responsibilitie The licensee has selected the Corporate Nuclear Maintenance Manage Inspection findings in regard to the involvement of the new corporate maintenance organizations in the maintenance programs are discussed in paragraphs 6.a and 9.f of this report. This item remains open pending completion of long term action (Open) Finding A- performance Indicator The corporate effort to identify and implement performance indicators is in the formative stages. Actions have been taken by plant management to use performance indicators in the maintenance area. These actions include implementation of SQA-199, Site Daily
Work List, Rev. O, to provide a basis for planning work loads and prioritie The inspectors noted that during morning meetings, supervisors at the site were required to provide information regarding the jobs scheduled, worked, and completed and the effectiveness achieved in their areas. In addition, the QA organization had implemented a program to report rejects to management. This item remains oper pending completion of long term corrective actio (0 pen) Finding A- Adequate Root Cause Analysi In NRC Inspection Report 327, 328/87-15, the inspector noted an apparent example of a failure to adequately identify the root cause of ar apparent generic failure involving gasket leaks of 4-inch Walworth swing check valves. The inspectors determined durira this inspection that the licensee had taken action in late 1983 and early l 1984 to replace the gasket material and correct these problems. The trending report reviewed had not indicated that action had been taken to correct the problem, therefore the engineer's conclusion to monitor the valves had not appeared to be adequate. The licensee's l actions to resolve this problem based on the additional information appears appropriat !
As indicated in NRC Inspection Report 327, 328/87-15, the history and trending program appears to contain adequate administrative controls to assure. adequate root cause identification for repetitive failures. The inspectors noted that other actions are being taken l by the licensee, including an Operability Look Back Program to '
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determine equipment operability, establishment of the Condition i
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Adverse to Quality Report (CAQR) program, and establ';hment of corporate directives and standards for root cause ani ysis. Restart and long term items from these programs have been ide tified by the licensee and are being tracked to resolution. Findi a A-4 will -
remain open until further experience is gained in the implementation of the history and trending program and until long term corrective actions have been implemente Planning and Scheduling (0 pen) Finding A-3. Corporate Guidance and Coordination of Maintenance Progra Inspection findings in regard to the involvement of the new corporate maintenance organizations in the maintenance programs are discussed in paragraphs 6.a and 9.f of this report. This item remains open pending completion of long term action (Closed) Finding C-1. Training for Maintenance Planner Inspection findings in regard to training for maintenance planners are discussed in paragraph 11 of this inspection repor The licensee has completed the actions required for restar The long implementation of the training curriculum for planners is being tracked in the Tracking and Reporting of Open Items (TROI) syste This item is close (Closed) Finding G- Use of Current Revision of Procedures and Drawing During the inspection, the inspectors did not identify any cases where maintenance was being performed with out of date procedures or drawings. The licensee conducted a QA surveillance, QSQ-S-87-019, dated July 20, 1987, which indicated that plant compliance with the requirements in this area was good. One case was identified where misinformation from a planner had resulted in the failure to verify that instructions included in several maintenance requests were curren (The instructions were later determined to have been current.) The licensee issued CAQR SQP-870779. The corrective action for the CAQR, which included issuing a letter to appropriate personnel to clarify the requirement and discussions with the planner, have been complete The inspector also noted that the methods used to assure current procedures and drawings are included in work packages had been changed since the inspection reported in the NRC Inspection Report 327, 328/87-15. The licensee had deleted AI-42, Distribution and Control of Plant Instructions, which required planners to perform this verification and SQM-2, Maintenance Management System, Rev. 24, had been revised to require that foremen verify that current
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i procedures and drawings are included in the work package This item is close (0 pen) Finding G-4. Coordination of Maintenance to Minimize Downtime, Testing and Radiation Exposur The licensee has implemented SQA-199,' Site Daily Work List, Rev. O, to provide additional coordination of maintenance work activitie Review of the implementation of this procedure is discussed in paragraph 7. The licensee is making progress towards improving the coordination of maintenance, however, since this procedure has only been implemented a short time, an assessment of the effectiveness was not possible. This item will be left open as a long term follow-up ite (0 pen) Finding G- Lack of Equipment Qualification Lis As documentea in NRC Inspection Report 327, 328/87-15, the licensee has implemented administrative controls providing guidance on the determination of equipment qualification requirements. This item remains open pending completion of long term actions to provide a single Q-list for the sit (0 pen) Finding N-2. Provide Hardware to Implement Effective Maintenance History and Trending Progra Corporate guidance for this effort is still in the formative stage This item will remain open pending completion of long term corrective actio ,
Maintenance ProcedJres and Review of Maintenance Work Request System
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(0 pen) Finding F- Failure to Follow Work Instructions and Procedure The inspection findings in this area are documented in paragraph 5 j of this report. The inspectors concluded that the licensee had taken reasonable actions to assure that work instructions are being )
followed in the short term. However, long. term management emphasis i will be required to assure effective implementation, therefore, this item will remain ope (0 pen) Finding F-2, Finding H- Work Instructions Not Clear, 1 Concise and Complet )
The inspection findings in this area are documented in paragraphs E, 8 and 9.c of this report. The licensee had proposed a long term Maintenance Instruction Enhancement Program to improve the quality j of maintenance instructions. The licensee has committed to provide l additional information ca this program by August 14, 1987. This
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item remains open pending completion of the long term progra Preventive Maintenance (0 pen) Finding E-1, Finding E- Inadequacies in Preventive Maintenance Progra I
Finding E-1: The inspectors reviewed the fallowing corrective actions in this area: Systematic review of systems and important equipment to ensure needed equipment is identified and .in condition for safe reliable operation; Maintenance groups review of CSSC equipment versus PM listing ,
and the Technical Specifications /FSAR for PM requirements and j needs; >
l l Revision of AI-19 " Plant Modifications" to ensure the modifications procedure contains provisions for updating the PM progra The inspector reviewed two memos titled Equipment Condition l Evaluation Report, from the Supervisor, Maintenance Program Assessment to the Maintenance Superintendent, 10 numbers L22 870211 800 and L22 87036 802. The memos detailed how the objective was accomplished and divided comments into thre'e areas: recommendations; considerations; and considerations for PM program. Recommendations have to be formally reviewed and dispositioned by the respective ,
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maintenance departments as to why a recommended test or maintenance !
l need not be performed or that it will be performed prior to startup 4 to ensure operabilit The considerations'for PM are also being i l handled in a similar manner. The inspector found that the equipment 'l condition evaluation provided a systematic review of plant !
equipment. The licensee identified needed equipment and assessed I the condition of the equipmen The inspector noted that numerous
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recommendations have been determined by the licensee to be required
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for startu). The actions taken by the maintenance and preventive maintenance organizations to complete these action items are being tracked o the P2 scheduling syste !
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I Memos were written to each maintenance section on February 18, 1986, i Sequoyah ID number S53 870220 932, requesting the following actions: j review Technical Specifications for any reference to vendor manual !
utilization; review FSAR for any reference to vendor manual utilization; review CSSC list and determine if there are any mechanical components which neeo prevu tive maintenance (PM), review l the vendor manual; review CSSC list eld ha e -lead engineers evaluate l l if existing PMs are inadequate. For ; hose determined to be l inadequate, review the vendor manualr.. Tne inspector reviewed each of the departments responses to the memo and concluded that a
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thorough review had been accomplished within reason. Exceptions such as not evaluating 100% of all CSSC equipment were justified and well documented. A vendor manual review of equipment is being conducted concurrently with the licensee's response to Generic j Letter 83-28 to be completed by January 1988. The responses '
identified that new PMs had been identified and were either already written and approved or were in the process. FSAR reviews identified the need for minor changes to the FSAR to clarify PM commitments. TS reviews identified very few instances of PMs required by Technical Specifications. The most notable of these was the surveillance requirement for Diesel Generators for which adequate PM existed. The licensee has identified the changes required due to the PM program review including those considered necessary for rastart in the Corrective Action Plan for NMRG Audit R-8r -02-NPS, Rev.1, dated May 13, 1987. These actions will be tracked via the P2 schedul I Plant Modifications, Part IV, Af ter Licensing, was revised in Rev.
22 to include provisions for updating the PM program after plant modifications.
Finding E-5: The inspector reviewed the following corrective actions: Maintenance groups review of TS/FSAR for PM requirements; Listing of TS/FSAR requirements versus PMs.
The inspector reviewed the documentation of the TS/FSAR reviews.
Final listings had been issued for Instrumentation and Control, Electrical Maintenance and Mechanical Maintenance departmen The inspector determined that a very thorough review of these regulatory documents had been accomplished and that all commitments were identifie In addition to the actions discussed above for Findings E-1 and E-5, the licensee has identified other actions to address problems in the preventive maintenance area. These include appointment of a PM Manager, development and implementation of a PM Upgrade Program, development of corporate guidance for the preventive maintenance program, review of equi ment condition operability, review of vendor manuals, development of specific new PMs, methods to allow cite input into the development of the corporate program, a review of appropriate PMs after modifications to the plant and determination of mandatory PMs. The review of these areas is documented in paraqraph 9 of this report. Many of the items require long term corrective actions, this item will remain open pending completion of these action (Closed) Finding E-3 . Lack of Management Approval for Waiver, Extension and Deferrals of Preventive Maintenanc ~
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NRC Inspection Report 327, 328/87-15 detailed an audit performed on cancelled.or deferred PMs and the subsequent actions taken as a result of this audit. At the time the changes were thought to be satisfactor An audit performed subsequent to the revision of procedures and forms found that the problem had not yet been effectively solve Licensee personnel indicated that the audit was probably premature, since the procedure revision had just been issued, to adequately assess the corrective action. The licensee conducted a second audit from June 30 to July 7, 1987. 1his audit had not been issued at the end of the inspection period, however, the inspector discussed the findings with the licensee. The audit indicated that the management approval process was being implemented, however, for seven PMs reviewed, the approval was documented after the PM performance due date. The licensee stated that SQM-57, Preventive Maintenance Program, would be revised to provide guidance that the deferral snould be signed within the grace r period of the performance date. This item is closed.
Post Maintenance Testing (PMT)
(Closed) Finding I- Adequate Definition and Performance of Post Maintenance Testin The review of post maintenance testing is discussed in paragraphs 10 and 11 of this report. -The licensee's short term corrective actions, including the revision of administrative procedures, addition of resources to the planning group, training on post maintenance testing for planners and QA reviewers, completion of an audit to confirm adequate PMT, and assurance that SQM-1 addresses PMTs for new and revised procedures, have been completed. The issuance of a procedure on PMT (SQM-66) had been completed. Long term actions to include PMT in procedures, provide input to corporate standards and preparation of equipment specific post maintenance testing is being tracked in the TROI system. Long term actions will be reviewed in conjunction with the Maintenance Instruction Enhancement Program and the review of corporate initiative The Plant Manager also issued a memorandum to managers at the site on the requirements for Plant Operations Review Committee (PORC)
review of work requests. This policy indicates that step-by-step written instructions should be included in PORC-approved procedures rather than submitted to PORC for review in a work request. The memo also provides additional guidance on the adequacy of post maintenance testin ,
The licensee conducted a quality engineering surveillance on the adequacy of. post maintenance testing from June 29 through July 9, 1987. The surveillance covered the areas of SQM-2 revision completion, designa+ %n of qualified reviewers', training for post n'aintenance test planning and review, adequacy of post maintenance
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post maintenance testing. One deficiency-was identified in the area j of qualified reviewers. A contract employee failed to provide a work package to a qualified reviewer for review prior to issuanc The licensee indicated that this individual had been counseled in the review requirement i This item is close Quality Assurance
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(Closed) Finding 0-1. Plant Quality Assurance Reviews Were Not i Identifying Significant Weaknesse As discussed in NRC Inspection Report 327, 328/87-15, the licensee has completed actions to separate QA reviewers into specialized <
discipline The inspectors also confirmed that additional training i of QA reviewers in the requirements of SQM-2 and post maintenance testing had been conducted. This item is close (0 pen) Finding 0- Corrective Action for Items Identified by QA Not Effectiv The site has implemented procedure AI-12, Corrective Action, which establishes the Condition Adverse to Quality Report (CAQR). The CAQR process will be reviewed in future inspection (0 pen) Finding 0- Inconsistencies in Nuclear Quality Assurance Manua i This item will be reviewed in future inspection j i
Deficiencies in the Rigging and Hoisting Program
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(Closed) Finding L- Rigging Identified as Defective Not Segregate !
The inspector accompanied by a cognizant licensee representative i inspected tool rooms in the turbine building, on the turbine deck and service building, to ascertain whether defective hoisting gear l (.ylon slings and wire rope chockers) were segregated in designated ]
areas and whether acceptable hoisting gear was being controlled in '
an appropriate manner. Discussions with tool room attendants and other cognizant personnel disclosed that gear in the tool rooms was treated as any other maintenance type tool issue The inspector determined that the craftsman completes TVA Form 6505 at the time of issue. This fc"m is kept on file until the gear is returned to the tool room. Afterwards the form is forwarded to records where the information is fed into a computer programmed to track the service history of the gear.
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l On the turbine deck the gear is kept in a locked tool crib roo l The gear is issued to craft working in this area only. Segregation I in this area is dictated by size and weight of the gear, i.e. , wire rope chocker of 2 inch diameter and 25 foot length. Presently where this type of heavy gear is tagged out as defective, it is not segregated because of handlir.g difficulties. Discussions with the
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licensee's cognizant materials officer disclosed that the licensee .
is developing a program to control issuance of all hoisting gear by l compute It is expected that this computer program will be issued I for implementation shortly. The program will maintain a complete history on all hoisting gear including the required testing which will be performed on an annual basis. The inspector audited hoisting gear and verified that the serial numbers complied with the identification requirements of Standard Practice SQM-31, Inspection, .
Testing, Maintenance, and Operation of Nuclear Plant Cranes and ;
Hoisting, and Rigging Equipment - Ref. DPM N74M15 Proj. Element 1401 )
TS 04.13.07, Rev. ]
In reference to the issue concerning the D/d ratio concept j applicable to wire rope slings used to lift objects whose diameter i of curvature is greater than the diameter of the wire rope (sling) l used. The inspectors noted that the licensee has posted large l posters at strategic locations (tool room wall), that provide )
specific information/ guidelines on the D/d concept and has conducted i training classes that addressed the aforementioned issue along with licensee policy on tagging, segregation and identification of damaged hoisting gear. The training session was attended by ;
maintenance personnel in the mechanical, electrical and ]
instrumentation crafts. A spot check was conducted to determine whether craft interviewed had attended the aforementioned training course. This record search indicated that the persons interviewed had attended the training. Because the licensee has taken appropriate steps to correct all the significant issues identified under Finding L-4, this item is close Teflon Tape Usage (0 pen) Finding A- Unacceptable Usage of Teflon Tape as Thread Sealan The licensee has implemented corrective actions at the plant through SQA-160, Materials Which May Come in Contact Wish Remor Coolan Actions committed to be complete at the plant site i nr 'estart are considered closed This item remains open pending completion of long term action including issuance of corporate guidance on the use of Teflon tap Design Change Process (Closed) Finding H-1. Minor Design Changes Needed to Support Plant Maintenance and Operation are not Being Accomplished in a Timely Manne ____ -
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SQEP-60, Handling of Modifications Using Design Change Notices, Re O, was issued on April 14, 1987. Discussions with the licensee indicated that procedtire AI-19, Plant Modifications, Part IV, was changed to provide the needed plant interface requirements on May 22, 1987. The first Design Change Notice (DCN) was issued under the new procedure on June 3, 1987 and approximately 20 DCNs have been processed utilizing the new process since that time. The new process requires interf ace only with disciplines involved in the modification rather than reviews and signoffs by numerous engineering disciplines. NRC Inspection Report 327, 328/87-42 documents the NRC's inspection of the design change process. The inspector also noted that the lic.nsee is reviewing the design / engineering change proceu and intends to revise SQEP-13, Procedure for Transitional Design Change Control, to implement long term program improvements in this area. NRC follow-up in this area will be as documented in NRC Inspection Report 327, 328/87-4 ,
The inspection determined that significant progress had been made in {
completing the corrective actions for the NMRG findings. NRC inspection in these areas identified only one new finding in regard to Finding F-1 concerning the failure to follow procedur The NMRG followup audit closed tnis item based on NMRG observation of procedural compliance. The NRC finding is discussed in paragraphs 5 and 10 of this repor The licensee's tracking mechanism for assuring that the remaining corrective actions are completed prior to restart was considered adequate. The inspection team concluded that the scheduled routine NRC audit of licensee restart commitrhents and activities was appropriate to assure completion of the remaining items and that, with the recogniMon that the licensee had additional actions to complete, the NMRG findings had been satisfactorily addressed for Unit 2 startu No violations or deviations were identifie . Inspector Followup Items (92701) (0 pen) Inspector Followup Item 327, 328/85-45-16. Masoneilan Valve Failures. The licensee has completed the actions required for startup in regard to this item. Tracking of Masoneilan valve failures will remain open to assess operational history of the valves, (Closed) Inspector Followup Item 327, 328/86-17-01. Completion of License Certification Lesson olans. The inspector reviewed selected lesson plans in the operator license certification progra In addition the inspector verified that appropriate topics as indicated in 10 CFR 55 were addressed in the certification progr The .
licensee had approved and issued all lesson plans for the sixteen j week certification program at the time of the inspection. This item 1 1.s closed.
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c. (Closed) Inspector Followup Item 327, 328/86-17-02. Implementation of Expanded Annual Requalification Training. The inspectors had previously identified concerns with the scope of requalification exams. The limitations in scope were attributed to the four-week time constraint on requalification training at that tim The licensee committed in the SNPP Section 11.2.3.2, Operator Training, to lengthened the duration of licensed operator training from four weeks to six weeks and add a six group rotation in order to provide one week in six for training. The licensee has implemented the six group rotation. The inspection reviewed the lesson plans for the 1986 and those written to date for the 1987 requalification training programs. The six week format was implemented in 198 T"is item is close d. (Closed) Inspector Followup Item 327, 328/86-17-03. Completion of Instructor Certification. Program for Two Instructor The concern involved two instructors who had not completed an instructor certification course in the 18-month time frame specified in Area Plan 0202.03, Instructor Certificatio The inspector reviewed Area plan 0202.03 dated September 12, 1985 and the training records for the two instructors and determined that the instructors had completed the certification course on June 18, 1986 and May 22, i 1986. This item is close !
W e. (0 pen) Inspector Followup Item 327, 328/86-17-04. Pre-startup Training Commitment The licensee committed to provide all operators with a training letter on major plant modifications completed during the extended outage, and additional startup simulator training for licensed employees who will be involved in the Unit 2 startup. In addition, the licensee committed to provide Unit 1 operators training on startup with a high boron concentration and potential positive moderator temperature coefficient prior to startup of Unit The licensee has not completed corrective actions for this item. The inspector verified that the commitments have been assigned and are being tracked as startup commitment This item remains open. This is a RESTART ite f. (0 pen) Inspector Followup Item 327, 328/86-18-05. Update Applicable Procedures to Specify Torque Switch Settings for Applicable Motor Operated Valves (MOVs). The inspector had determined that procedure MI-11.2A, Limitorque Actuators Corrective Maintenance Procedure for SB-00, SMB-000, and SMB-00 Actuators, did not specify torque switch
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setting The licensee determined that thrust rather than torque switch settings should be controlle The licensee indicated that MI-10.43, Procedure for Testing Motor Operated Valves Using MOVATS System, would be revised to include thrust values and MI 11.2A and 11.20 would be revised to require MOVATS testing to be repeateo if a torque switch is ' replaced or the actuator is disassemble The inspector reviewed MI-10.43, Rev.' 5. The procedure had been revised to include required and maximum thrust values for motor operated valves. Procedures 11.2A and 11.2B had not been revised. This item
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remains ope g. (0 pen) Inspector Followup Item 327, 328/86-18-06. Review of the 1 Maintenance Instruction Rewrite Program. This area was addressed.in j inspection report 327, 328/86-18. At that time the program had not i progressed sufficiently to determine the adequacy of maintenance I instruction rewrites. During this inspection the licensee provided l the following update on maintenance procedure rewrite in accordance with the new writers guid .
Mechanical Maintenance - 142 procedures required, 11 procedures .,
rewritten and PORC approve t Electrical Maintenance - 82 procedures required, 8 procedures i rewritten and PORC approve Instrument Maintenance - 330 procedures required, 10 procedures rewritten and approve The inspector obtained a copy of two PORC approved mechanical maintenance procedures and reviewed these procedures based on the requirements of SQM-1. These procedures were:
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MI-10.2.1, Revision 0, " Removal, Inspection and Replacement of Reacter Coolant Pump Seal l
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MI-12.4.1, Revision 0, " Removal and Reinsta11ation of Flow Element Orifice Plate in any Syste No discrepancies were'noted in these procedure reviews. However, the inspector considers that additional. inspection is required to adequately assess this area The licensee has committed to provide a description of the MIEP, a schedule for implementation, and plans for finalization of the corporate writer's guide by August 14, 198 ,
This item will remain ope '
h. (0 pen) Inspector Followup Item 327, 328/86-48-02. Technical Support Systems Engineering Section Implementation. Refer to paragraph of this repor . (0 pen) Inspector Followup Item 327, 328/86-48-05. Complete Restart Maintenance Action. The licensee had not comple+ed corrective ,
actions for this item. This is a RESTART ite (Closed) Inspector Followup Item 327, 328/86-60-12. Followup of Control of Stored Equipment. This item involved a followup review of the methods used to assure that stored equipment was maintained in accordance with the vendor manual storage requirements and appropriate PMs were performed. The inspector reviewed the implementation of storage requirements in unresolved Item 327, 328/86-18-07~as discussed in paragraph 3.1 of this report. This 1 J
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l item is close k. (Closed)' Inspector Followup Item 327, 328/87-15-01. No Followup Method to Ensure That the Safety Evaluation Report on M&TE Completed Within 14 Days. The inspector had noted that there were no provisions to ensure that safety evaluations for out of calibration M&TE were completed within 14 days as required by AI-31, Control of Measuring and Test Equipment. The inspector reviewed Rev. 8 of AI-31. The procedure had been revised to incorporate a requirement that, 10 working days after initiation of an Out of Tolerance report, the evaluation package shall be hand-carried to the Plant Operations Review Staff (p0RS) and P0RS shall complete the safety l evaluation. This item is closed.
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