IR 05000458/1986006
| ML20211P399 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 06/24/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8607230208 | |
| Download: ML20211P399 (21) | |
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JUN % 41986
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In Reply Refer To:
Docket: 50-458/86-06 Gulf States Utilities ATTN: William J. Cahill, J Senior Vice President River Bend Nuclear Group P. O. Box 2951 Beaumont, Texas 77704 Gentlemen: -
This refers to the inspection conducted by Mr. J. R. Boardman of this office and three consultants during the periods February 3-7 and March 3-7, 1986, of activities authorized by NRC Operating License NPF-40 for the River Bend Station, and to the discussion of our findings with you, and other members of your staff, at the conclusion of the inspectio Areas examined during the inspection included the River Bend Station maintenance program, implementation of the maintenance program in the electrical, instrumentation and control and mechanical disciplines, and the licensee's Quality Assurance program (Maintenance). Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. The inspection findings are documented in the enclosed inspection repor During this inspection, it was found that certain of your activities were in violation of NRC requirement Consequently, you are required to respond to this violation, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter, and should include your actions to assure that the identified procedural inadequacies have not adversely affected equipment and systems that could affect nuclear safet Although certain of your activities were found to be in violation of NRC requirements, the NRC inspector observed a positive philosophy of technical excellence on the part of senior station management. This philosophy appeared to be the reason that procedural inadequacies did not result in identified hardware deficiencies. This upper management involvement, with its resultant positive influence on plant and technical support staffs, is commendabl The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96- 1 $
RIV:RSB/ES JRBoardman/tw ES OS [ c h JPJaudon P.? RSB N RPB JEGaglif o REIrelandfMHunnicutt l,/19/86 6/ M f4/l7/86 6/l7/86 f/fl/86 */p/86[TFWesterman g
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Gulf States Utilities -2-Should you have any questions concerning this inspection, we will be pleased to discuss them with yo
Sincerely,
..oristnal S'8"*d u. E. GAGLIARDOf5 J. E. Gagliardo, Chief Reactor Projects Branch
Enclosures:
Appendix A - Notice of Violation Appendix B - NRC Inspection Report 50-458/86-06
REGION IV==
NRC Inspection Report: 50-458/86-06 License: NPF-47 Docket: 50-458 Licensee: Gulf States Utilities Company P. O. Box 220 St. Francisville, Louisiana 70775 Facility Name: River Bend Station Inspection At: St. Francisville, Louisiana 70775 Inspection Conducted: February 3-7 and March 3-7, 1986 Inspector:
J. R. Boardman, Reactor Inspector, Operations Date Section Accompanied by: Luther Jones, EG&G Howard Stromberg, EG&G Dean Summers, EG&G Approved By:
D. M. Hunnicutt, Chief, Operations Section Date Inspection Summary Inspection Conducted February 3-7 and March 3-7, 1986 (Report 50-458/86-06)
Areas Inspected: A Region IV routine, announced team inspection of licensee maintenance activities was made, covering maintenance program, maintenance program implementation, instrumentation and control (I&C) maintenance, electrical maintenance, mechanical maintenance, and maintenance program Q Results: Within the six areas inspected, one violation was identified (failure to have procedures for activities affecting quality). This violation included several example '
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DETAILS Persons Contacted
- + J. Cahill, Jr. , Senior Vice President, River Bend Nuclear Group
- +J. C. Deddens, Vice President, River Bend Nuclear Group
- +T. L. Crouse, Manager, Quality Assurance
+ H. Odell, Manager, Administration
- + W. Helmick, Director, Projects
+W. J. Reed, Director, Nuclear Licensing
- +T. F. Plunket, Plant Manager
- +D. M. Reynerson, Director, Nuclear Plant Engineering
- +P. F. Tomlinson, Director, Quality Services L. R. Cummings, Mechanical Maintenance Foreman
- J. D. Davis, QA Engineer
- +D. R. Derbonne, General Maintenance Supervisor
- +K. E. Suhrke, Manager, Projects Planning and Coordination
+A. O. Fredieu, Assistant Operations Supervisor
- +E. R. Grant, Supervisor, Nuclear Licensing J. L. Frick, Electrical Maintenance Foreman
- +J. R. Hamilton, Supervisor, NSSS Projects J. D. Hatcher, Maintenance Planning
+ K. Henry, Electrical Supervisor, Nuclear Plant Engineering B. E. Hey, Nuclear Licensing Engineer
+R. J. King, Licensing Engineer D. E. Hill, Construction Engineer, SWEC
- +D. R. Gipson, Assistant Plant Manager, Operations, Chemistry, and Radiological Waste
- +A. O. Kowalczuk, Assistant Plant Manager, Maintenance & Material
- R. B. Stafford, Director, Operations QA W. T. Laib, Mechanical Maintenance Foreman
- +I. M. Malik, Supervisory Quality Engineering
- +P. E. Freehill, Superintendent, Startup and Test
- L. Schell, Senior Electrical Engineer J. E. McGee, QC Inspector
+ O. Moffatt, Quality Engineer
- +J. H. McQuirter, Nuclear Licensing
- J. J. Zullo, Quality Assurance Manager, Nuclear Parts
- J. D. Mullin, Maintenance Planner
+J. E. McWorter, QA Engineer K. J. Giadrosich, Senior Quality Assurance Engineering Supervisor J. Price, Nuclear Licensing
- + F. Roark, Electrical Maintenance Supervisor E. M. Cargill, Health Physics Supervisor
- D. G. Seymour, Compliance Analysis C. L. Fantacci, Radiation Protection Supervisor E. P. Shankle, Shift Supervisor i
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A. J. Stepanavich, Quality Control (QC) Planner D. E. Zemel, Maintenance Engineer R. F. Mendenhall, Electrical Maintenance Foreman S. D. Justice, Electrical Maintenance Foreman
- C. R. Maxson, Compliance Analyst
- T. Murphy, Planning F. J. Allison, I&C Foreman
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- C. W. Walling, Quality Assurance-(QA)
+A. Soni, Nuclear Power Engineering
, +P. F. Gillespie, Senior Compliance Engineer
+R. R. Smith, Licensing Engineer
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H. J. Huff, Management Systems 4 *+A . E. Bailey, Operations QC Supervisor J. A. Taylor, Material Supervisor R. E. Forster, Mechanical Maintenance Foreman
+ E. Kook, Nuclear Power Engineering, Electrical B. E. Bickel, I&C Foreman
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D. Reynolds, Supervisor, Document Control e
S. Marino, Training The NRC inspector also interviewed additional licensee and contractor personnel during the inspectio * Denotes those attending the exit interview on February 7,198 + Denotes those attending the exit interview on March 7, 198 "
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The senior resident and resident inspectors attended both exit interview . General Maintenance Program I
The NRC inspector performed a review of the River Bend Station maintenance program, including selected administrative and maintenance procedure Organization and Administration The assistant plant manager, maintenance and material, reports directly to the plant manager. He is in charge of the maintenance 9 engineer, the supervisor of purchasing and material, and the general maintenance superviso The general maintenance supervisor manages maintrenance discipline supervisors in the fields of mechanical, building and grounds, electrical, and instruments and controls (I&C). Each discipline supervisor has foremen who supervise the individus; craftsmen and planners for detailed Maintenance Work Requests (MWR).
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The total number of supervisory. levels, including foreman to assistant plant manager, is four. Foremen supervise five to ten craftsme Higher level maintenance management supervise from two to six at the next lower leve Maintenance problems and technical issues are resolved by various committee These include the Facility Review Committee, the Technical Staff Reliability Program, the Nuclear Safety Board, and the Independent Safety Engineering Group. These are supplemented by task forces working on specific maintenance problems. At the time of the inspection, approximately 20 task forces were activ In addition, River Bend management supports staff participation in nation-wide maintenance-related groups, such as INP0 Accreditation teams for maintenance training, the Nuclear Utilities Management and Human Resources Committee (NUMARC), the Nuclear' Plant Reliability Data System (NPRDS), and the Pooled Inventory Management System (PIMS).
Some overlapping functions exist in areas such as vibration analysis, equipment qualification maintenance, and routine preventive maintenanc Planned outages are coordinated by the Outage Management Group,-whose superintendent reports to the plant manage Individual. task planning is done by maintenance planners, b. Policies and Procedures TheRiverBendStationhasprocedurescovering[ maintenance activities, both preventive and correctiv IMervice inspection, equipment qualification, surveillance testing, and maintenance testing are included in the syste Corrective maintenance, preventive maintenance, and predictive maintenance programs are defined and controlled by administrative procedures (ADM). No goals or objectives for these programs had been publishe River Bend had operated only 5 months, at limited power, so feedback from operating experience was not available in many instance River Bend has a system for emergency maintenance (prompt maintenance MWR). The shift supervisor uses this system as a method of processing maintenance requests which require solution without waiting for day-time processing and planning step Approximately 20 percent of the River Bend surveillance testing is not required by regulations or ASME code requirements. The results l
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of surveillance testing are used for equipment reliability analysis, predictive maintenance, planning preventive taintenance, and planning corrective maintenanc In the current fiscal year, approximately 75 percent of maintenance is budgeted for corrective maintenance with the balance for preventive maintenance. Since the plant has been performing low power testing since criticality 5 months ago, actual figures are not known, but most expenditures have been for corrective maintenanc The plant staff designs and installs all major modification ,
c. Administrative Control The licensee uses the computer-based Plant Maintenance System (PMS)
to determine the status of outstanding work orders and for maintenance p'annin It is the only system used for maintenance tracking duri'g either normal operations or outage The outage supervisor, in the Engineering Services organization, plans all scheduled outages. For normal operations, each discipline supervisor has his own planning organization. In either case, detailed job planning is performed by planning and scheduling specialists who work for the discipline supervisor The maintenance management periodically uses a computer program to calculate performance indicators for each foreman. Thus, comparative data for each foreman are continuously evaluate Maintenance management is aware of the NUMARC maintenance performance indicators, and intends to monitor these. Since plant operating experience is limited, the most reliable indicators of maintenance effectiveness are not yet establishe As a result of the Davis-Besse event, design calculations for. valve operators have been reviewed, and all valves have been checked for proper setting *
Operating personnel were made aware of the potential problem, and all-operational problems'at River Bend are carefully studied to assure no generic problems exis .
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d. Communications and Interactions With Other Departments .
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Communication and interactions between Maintenance and the other departments are described belo (1) Quality Assurance and Quality Control (QA/QC)
Specific lines of communication between QA/QC and Maintenance are defined in QC's administrative procedures and maintenance procedures. Quality Assurance and Quality Control report to the
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same manager. QC reviews all safety-related and most nonsafety related MWRs and adds hold points as required. The hold points are identified on the maintenance procedures during review of the maintenance work packages. Approximately 85 percent of QC inspector-hours are spent on safety-related equipment; the inspector to maintenance mechanic ratio is about 1: The average experience of QC personnel is 9.5 years, with most having prior nuclear maintenance experience. The operations QC supervisor has 13 years nuclear QC experience, 4 years of which have been at River Bend. Quality Assurance Engineering (QAE)
has an audit group with five full-time auditor (2) Plant Engineering The specific lines of communication between technical services and maintenance are defined in administrative procedures. The technical service group reports to the assistant plant manager of technical services and is an onsite organizatio It participates actively in INP0 and other NPRDS program (3) Health Physics Specific lines of communication between health physics (HP) and maintenance are defined in administrative procedures. All MWRs requiring access to radiologically controlled areas require a Radiation Work Permit, which specifies the controls require Work in radiation levels over 2.5 R/hr or doses expected to exceed 10 man-rem require ALARA revie Briefings of the mechanics, area maps, and continuous HP monitoring in high radiation areas are used to limit radiation dose Radiation exposure is tracked in the six basic categories required by NRC, as well as by job. Total radiation dose per year for the site is not presently used as a maintenance performance indicato (4) Maintenance Staff Mechanical, electrical, and instrument staff personnel experience varies considerably, from 9 to 12 years for instrument and mechanical to 1.5 years for electrica Supervisors' experience in all crafts runs from 10 to 25 year Coverage of work by supervisors above foreman varies from 10 percent in I&C to 75 percent in electrical. All maintenance staff people interviewed felt they received adequate support from engineerin The maintenance people estimated they spent 60-80 percent of the day in useful maintenance work if briefings and document review are counted as useful wor QC monitors
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most safety-related work by using hold points. Sixty to eighty percent of safety-related work is monitored by QC. I&C personnel performing troubleshooting or preventive maintenance are not monitored by Q e. Facilities and Equipment
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The River Bend maintenance facilities and equipment are described belo The craft workshops were sized using experience at other plants as much as possible, and the size of the various shops appears adequate from the standpoint of work space to avoid any adverse effects on the quality or efficiency of maintenance work done at the plan ALARA considerations permitting, most mechanical work is performed at the equipment location. The electrical and I&C crafts perform maintenance in the shop area or in the plant. Electrical work is occasionally limited by the need for an area equipped with heavy hoisting equipmen I&C has 60 work spaces in 2 areas, and Electrical has 20 work space The mechanics work spaces are not defined. Maintenance has not been affected by lack of work spac Two tool cribs are available; one for clean and the other for contaminated work. A study of tool crib size and location has been performed by outside consultants, but no modifications are planned until more operating experience is gained. All tools are stored in the tool cribs except the individual mechanic's tools and the machine shop's tools. Availability of tools or tool crib space has not affected mainte.1anc Contaminated tools may be decontaminated or restricted to the contaminated tool crib. Calibration of contaminated tools such as torque wrenches is usually accomplished with special standard The size and permanent location of the contaminated storage area will not be determined until more operating experience is gaine The warehouse size is adequate, and all items are stored there, with the exception of extremely bulky materials and some special item The distance of the warehouse from work areas apparently causes some inconvenienc f. Licensee Procedures Reviewed
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The following licensee procedures were reviewed:
(1) ADM-0003 " Development, Control and Use of Procedures"
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(2) ADM-0006 " Control of Plant Records" (3) ADM-0015 Revision 7, " Surveillance Test Program" (4) ADM-0018' " Plant Housekeeping and Cleanliness Codtrol" i
i (5) ADM-0019 " Initiation and Processing Condition Reports" (6) ADM-0023 - Revision 5, " Conduct of Maintenance," dated November 18, 1985 . .
(7) ADM-0027 Revision 3, " Protective Tagging," dated September 14,
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(8) ADM-0028 Revision 4, " Maintenance Work Request," dated
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- (9) ADM-0030 Revision 3, " Reporting and Processing Nonconformances" (10) ADM-0048 Revision 0, " Performance Monitoring and Trend Analysis," dated October 16, 1985 (11) NUPE-AA-41 Revision 1, " Evaluation of Interchangeability of Spare Parts" i (12) NUPE-AA-42 Revision 1, " Evaluation and Justification of Commercial Grade Spare Parts" (13) NUPE-AA-65 Revision 0, Vendor Manual Applicability Review
, (14) CMP-1253 Revision 3, "Limitorque Motor Operated Valves," dated February 3, 1986
- (15) CMP-9136 Revision 1, Velan Motor Operated Gate Valve . . .
Disassembly, Inspection, Rework, and Assembly (16) FPP-0060 " Hot Work Permit" (17) GMP-0015 Revision 2, " Lubrication Procedure," dated December 5, 1985 (18) GMP-0018 " General Torquing Guide"
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(19) GMP-0042 " Control Circuit Testing" (20) GMP-0068 " Disassembled Components Identification and Control" (21) MCP-4000 Revision 2, " Device Calibration," dated December 17, 1985 (22) MCP-4001 Revision 0, " Loop Calibration," dated May 29, 1984
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(23) MCP-4068 Revision 2, " Calibration of Rosemount Model 1153 Transmitter," dated October 16, 1985 (24) MHP-0012 Revision 0, " Return of Material to the Storeroom,"
dated December 24, 1985 (25) MSP-0002 " Corrective Maintenance Program"
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(26) MSP-0003 Revisions 3 and 4, " Preventative Maintenance Program" (27) MSP-0005 "Special Maintenance Process" (28) MSP-0009 Revision 5, dQualification of Maintenance Personnel,"
i dated November 6, 1985 (29) MSP-0011 " Certification and Training of Personnel for Special Processes" (30) MSP-0014 " Housekeeping" (31) MSP-0021 Revision 2, " Equipment Removal. Tagging," dated January 13, 1986 (32) NPE-3-007 " Instructions and Requirements of Use of the River Bend Q-List"
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(33) PMP-1205 Revision 3, " Motor Operated Valve Routine
Maintenance," dated November 26, 1985
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(34) QAl-2.1 Revision 2, Audit Performance and Reporting
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(35) QAD-9 " Control of Special Processes"
! (36) QAP-1.3 Revision 4, " Quality Assurance Indoctrination and Training Program Procedure," dated May 7, 1985
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(37) QAP-1.5 Revision 4, " Certification of Nondestructive Examination Personnel," dated August 23, 1985 (38) QCI-3.2 Revision 2, " Inspection of Maintenance Activities
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Associated With Maintenance Work Requests," dated January 14, 1986
- (39) STP-000-3606 Revision 0, "Section XI Safety and Relief Valve
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Testing," dated June 25, 1985 (40) STP-209-0601 Revision 2, " Return of Material to the Storeroom," dated December 24, 1985
- (41) STP-305-1100 " Battery Weekly Surveillance Test for Battery
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(42) STP-309-0201 " Diesel Generator Division 1 Operability Test" (43) Gulf State Utilities Quality Assurance Manual (44) Quality Assurance Department Training, Qualification and Certification Manual g. Failure to Have Procedures for Activities Relating to Maintenance The NRC inspectors noted several areas of apparent procedural inadequacies relating to the maintenance area as follows:
(1) Incorporation of Vendor Technical Information in Maintenance Procedures At the time of this inspection the licensee had not incorporated in plant maintenance procedures certain vendor technical information available on site. This concern was first identified by the licensee in Quality Assurance Finding Report (QAFR) No. 0-84-10-35E, dated October 1, 1984, and QAFR E-84-11-280, dated October 31, 1984. Subsequent audits such as GSUS/EQAL-85/08 and 85/10, and QAFR 0-86-01-14-D have identified that this problem had not been resolve The NRC inspector found vendor specified maintenance for the RCIC turbine (see paragraph 6.e), safety-related Rosemount transmitters, and containment cooling fan motors had not been incorporated in licensee maintenance procedure The licensee had no procedure that required review of vendor equipment technical information relating to maintenance, and its adaption and incorporation into site maintenance procedures, prior to performance of maintenance on the equipmen ,
(2) Configuration Control for Maintenance Procedures Containing Vendor Technical Information (VII)
The license did not identify in site maintenance, procedures the revision of VTI incorporated; nor did they'have a system that could identify the applicable revisions of VTI that were incorporated. When new revisions of.VTI were' received, they were added to a master computer list, but were not highlighted or otherwise identified. No licensee procedure required review and incorporation in maintenance procedures of re' visions to VT '
(3) Periodicity Requirements for Maintenance of Qualification of Equipment Qualification Licensee maintenance procedures began periodicity at fuel loa As discussed in paragraph 5, the licensee allowed a +25 percent time interval on periodicit Some manufacturers specify periodicity to begin at the date of manufacture. Examples are capacitors and Agastat relays. Equipment Qualification (EQ)
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periodicity, and some other equipment periodicities, allow no plus tolerance. The licensee's generic +25 percent tolerance had been established without apparent consideration or review of exception (4) Root Cause Analysis The licensee is committed to Regulatory Guide 1.33, ANSI Standard N18.7-198 N18.7-1976, Section 5.2 7.1, states that the causes of malfunctions shall be promptly determined, evaluated, and recorded. The licensee could not identify a procedure to assure that this requirement is fulfille (5) Conclusion River Bend Station Technical Specification 6.8.1.a requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978. RG 1.33, Revision 2, Section 9 requires procedures for performing maintenance. Furthermore, 10 CFR 50, Appendix B, Criterion V requires procedures for activities affecting qualit The failure to have administrative procedures requiring the incorporation of VTI in maintenance procedures and requiring revision control and use of the latest VTI, the failure to have procedures properly controlling the periodicity of preventive maintenance, and the failure to have procedures implementing root cause analysis, as set forth in ANSI 18.7, Section 5.2.7.1, is an apparent violation of River Bend Technical Specifica-tion 6.8.1 and 10 CFR 50, Appendix B, Criterion V. (458/8606-01)
h. Summary
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The River Bend plant had been operating at limited power for approximately 5 months at the time of the inspection. As a result, there has been limited maintenance program feedback, such as location of hot laydown areas, tool crib design and location, full implementation of the preventive maintenance program, inservice inspection programs, predictive maintenance programs, and maintenance of equipment qualifications. River Bend had not completed actions related to Generic Letter 83-28, the Salem ATWS ever.'.
All personnel who were contacted demonstrated professional knowledge of the plant and their responsibilities, and enthusiasm and pride concerning plant activities.. The licensee demonstrated a positive attitude toward maintenance. An example noted by the inspector was the aggressive manner in which they accomplished a detailed inspection program of Limitorque actuators after one had faile Other examples included their program for refurbishment of AKR 30 and
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12 50 circuit breakers, and their performance of a detailed internal QA audit to ensure that their maintenance program was performing as intended and that document storage was adequat . Mechanical Maintenance Program In the mechanical maintenance area, the NRC inspector performed an inspection of maintenance history, work item tracking, and maintenance work request The following Mechanical Maintenance Organization personnel were interviewed to determine their areas of functional responsibility and their qualifications: maintenance supervisor, mechanical foreman, inspector, parts specialists, and welding engineer. The QA manager was also interviewe The following Maintenance Work Requests (MWR) were reviewed:
MWR 12570, " Service water to RHR testable check valve" a request to correct a nonfunctioning valve open indicator No.1E12*A0V F098; this MWR superseded MWR No. 007101, MWR No. 11587, "RWCU A Pump Suction Valve" a request to repair a packing leak on valve No. 1G33*M0V F001, and MWR No.14750, " Injection Valves on RHR and LPCS Systems" a request to inspect the worm gears on four valves; 1E12*MOV F042A, B, C, and Each MWR was checked for authorizing signatures, functional testing, spare parts control, adequacy of inspection, mechanical qualification, adequacy of descriptive portions detailing the maintenance performed and functional testing and restoration. The MWRs were reviewed to determine if the requirements of Administrative Procedure ADM-0023, Revision 5 " Conduct of Maintenance," ADM-0027, Revision 3 Protective Tagging, and ADM-0028, Revision 4 " Maintenance Work Requests," had been incorporated. No violations or deviations were identifie . Instrumentation Maintenance Program, Observation of Work, and Review of Quality Records The NRC inspector performed an in-depth review of the maintenance program in the instrument and control areas. Maintenance history, calibration records, qualification records, procedures, work item tracking forms, and maintenance work request forms were obtained and reviewed. The following I&C Maintenance Organization personnel were interviewed to determine their area of functional responsibility, and qualifications: I&C Supervisor, I&C Foreman, and technician _ __ - __________ -_-
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Fifteen completed maintenance packages were reviewed. The following six were considered to be significant enough to warrant further review:
- MWR No. 13234, HPC Flow Transmitter Maintenance, MWR No. 007223, RHR-A Room Level Indicator, MWR No. 10282 APRM-B Out of Tolerance (the MWR requirements had been shifted to MWR No. 13837),
MWR No. 13837, APRM A & MWR No. 13456, RWCU Demineralizer Room 1, and MWR No. 19173, APRM During the review of these packages, a concern was identified. MWR No.13234 requires the performance of maintenance of the HPC flow transmitter. The work requirements referenced a nonconformance report (NR) No. 85NR0391-00. A copy of the NR was attached to the MW When the NR was reviewed by the NRC inspector, it was found to identify work that was performed approximately 2 months earlier. It was not clear how this NR was applicable, what work was done, and what sequence of steps was used to perform the work. The licensee reviewed this item and provided an explanation during the second week of the inspection. The explanation adequately addressed the concer Two maintenance-related activities were witnessed to verify compliance with the appropriate maintenance procedures. These activities were the performance of two surveillance test procedures (STP-505-4507 RPS-APRM Weekly CHFUNCT, Weekly CHCAL (C51-APRM G) and STP-207-4247, Reactor Water Cleanup System Isolation Equipment Area Differential Temperature High Monthly CHFUNCT, 18-Month CHCAL, 18-Month LSFT (E31-N619B)). One concern was identified during the performance of STP-505-4507. This test required jumpers to be installed in a confined space. The terminals on which they are installed are in close proximity to other terminals. When the jumpers were installed, the technician shorted the terminals together resulting in arcing and a blown fuse. When questioned, the technicians indicated that this condition had been experienced before. They also identified a Modification Request that had been initiated which would install a patch panel to eliminate the requirement for a jumper to be installed in the confined space. This proposed modification satisfies the concer Maintenance of the qualification of safety-related Rosemount 1153 transmitters was reviewed. It was determined that if Maintenance Procedure MCP-4068 (Calibration of Rosemount Model 1153 transmitters, Revisions 0, 1, and 2) were used, equipment qualification could be voided because of omitted maintenance qualification requirements. On February 12, 1986, after this was brought to the attention of the licensee, a temporary change notice was issued to correct this procedur In addition, records for corrective maintenance and preventative maintenance were reviewed by the NRC inspector to determine if
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qualification had been compromised for any safety-related instruments because of the omitt ed requirements. No preventive maintenance had been performed using the improper requirements. Corrective maintenance had been performed, but this did not require performance of maintenance that would have voided qualificatio Records of performance of 15 Surveillance Test Procedures (STPs) were reviewed to determine if o-rings had been replaced, lubricated, and instrument covers torqued on safety-related Model 1153 Rosemount
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transmitters as required to maintain qualification. Twenty-two functional checks had been performed on Rosemount transmitters. The functional checks did not require removal of the protective covers and therefore, did not require o-ring replacement. Six STPs required instrument recalibration. In those six cases, the o-rings were properly replaced and the protective cover properly installed and torque . Electrical Maintenance Program Observation of Work and Review of Quality Records The NRC inspector performed a review of the licensee's electrical maintenance program and applicable River Bend administrative and maintenance procedures. Maintenance history, work item tracking forms, maintenance work requests, qualification records, document control procedures, and replacement part records were reviewed. The following Electrical Maintenance Organization personnel were interviewed to determine their area of functional responsibility and qualifications:
electrical supervisor, electrical foremen, and electrician Procedures and documentation associated with four completed maintenance activities were reviewed. The completed activities were:
MWR No. 24114, HPCS CST Return Valve Maintenance (which had been shifted to MWR No. 6569),
MWR No. 6569, Limitorque SMB-4 Motor Operator MOVs Maintenance (the HPCS CST Return Valve M0VF011 part only),
MWR No. 2954, IEE*MOVF023 Maintenance, and
- MWR No. 17338, Division 1 Standby Diesel Generator Maintenanc ' No violations or deviations were identified during the review of these package Work associated with two MWRs was reviewed to insure that licensee personnel performing work followed the appropriate maintenance work requests (MWRs). The MWRs were:
MWR No. 006573, Various Limitorque Actuators Torquing (1-SWP*M0V-55B only),
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MWR No.19120, Feedwater Pump IC Maintenance (only until bearing was removed).
Two problems were identified during the performance of MWR No. 00657 MWR No. 006573 was issued to cover the performance of yoke bolt torquing on several types of Limitorque actuators. Inspection hold points, included on the work package during the review process, were specified for the different types of actuators involved. Since the work was done on different actuators, not all hold points were applicable for each actuator. When the work was done, the nonapplicable hold points were left blank. By leaving these points blank, the licensee failed to follow Section 3.3.3 of QC Procedure QCI-3.2, Revision 2. The requirement by their procedure was to get a QCS to waive the hold point. This was not done. The second concern identified was that a signed-off copy of MWR No. 006573 was not used in torquing on valve ISWP*MOV-55B; a copy of the original was used. It was determined that the appropriate approvals had been obtained and were in the master MWR documentation package in the electrical shop. The work package made for valve maintenance was prepared before sign-offs had been obtained. The licensee explained that this MWR had been issued to cover the same work on a large number of valves and that a separate package had been made for each valve by copying the origina In generating work packages this way and not having a signed-off copy of the MWR at the work site, the licensee failed to follow step 5.9.6 of their Administrative Procedure ADM-0028, Revision 4. The licensee revised Procedure ADM-0028 to address the requirement for having an original signed-off MWR copy at the job site for review. The revised procedure deleted the requirement for having an original photo copy. A revision to Quality Procedure, QCI-3.2, was submitted to more clearly delineate the limitations of a QC inspector. The change also added words that nonapplicable steps would be marked as not applicable, initialed, and dated, rather than being left blank. These failures to follow procedures constitute an apparent violation; however, immediate and satisfactory corrective action was taken to prevent recurrence, and the licensee is not required to respon Another concern, which appears generic, was identified during the inspection. EQ preventive maintenance is identified on the PM schedule with all other PM. It is not identified as EQ. By the licensee's procedures, PM periodicity can exceed the specified interval by 25 percent of the periodicity time span. A 10-year-interval could be automatically extended to 121 years before the maintenance is considered to be late. In some cases the 25 percent late criteria could cause qualified equipment to lose its qualificatio The licensee responded by changing their EQ maintenance identification so that it is uniquely identifie The EQ maintenance timing requirements were also changed so that maintenance will be performed before qualification is los e *
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16 QA Program (Maintenance) General The NRC inspector reviewed the licensee's QA program implementation for maintenance activities in conformance with the Technical Specifications, regulatory requirements and committed industry standards. These requirements were found in the QA manual, QA directives, administrative, maintenance (electrical, mechanical, and instrument and control), operations and engineering procedure Personnel from each organization were interviewed concerning implementing these requirements. Additionally, MWR packages were reviewed to determine implementation and compliance with procedure Some procedure requirements appear subject to more than one interpretatio Specific differences in interpretation of procedure requirements are:
o Review and determination of malfunction and cause of failures o Trending analysis of failures o Identifying of safety /nonsafety jobs in the MWR by the shift supervisor and the maintenance planne Trend Analysis There was little evidence that trend analysis is performed on the causes of safety-related equipment malfunctions or failures. This will be reviewed further during a subsequent inspectio Maintenance Document Closure The NRC inspector did not find a procedure that identified the documents to be included in the completed (closed) MWR package When reviewing completed MWRs, it could not be determined if minimum required documents were included in the stored document file CFR 50, Appendix B, requires sufficient records be maintained to document activities affecting qualit During the second week of the inspection, the licensee submitted a revised document control procedure (ADM-0028). The administrative procedure was revised to identify the documents necessary for storage as part of the MWR package. This appears to adequately address the concer Material Control and Traceability An observation was made concerning control of installed material in safety-related system ,
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MWR No. 003773 required two spiral wound metal-asbestos gaskets to be installed in orifice flanges. These items were withdrawn on a stores requisition (SR) 28701, dated November 26, 1985, and its yellow copy added to the MWR package. The MWR number was recorded.on SR28701, but the stores requisition number was not recorded on the MW Personnel interviewed stated that the yellow stores requisition copy may not be included in the MWR permanent files. When the gasket was installed, material identification numbers were not recorded in the MW Personnel who were interviewed informed the NRC inspector that, to determine the identity of installed parts, one must go to the warehouse and have the original stores requisition retrieved. This method does not assure parts withdrawn are the parts installe Three MWRs (002526, 002527, and 002675), requiring fabrication and installation of parts in safety-related systems, were randomly selected from document storage files. The licensee was requested to provide material traceability for these parts. Of the three MWRs, the licensee was.able to provide evidence of acceptability for one (002675).
Material acceptability was not provided for the other two. This item is considered unresolved pending further review by the NRC inspector to determine whether material acceptability has been established (458/8606-02).
e. Incorporation of VTI The RCIC turbine manual preventive maintenance (PM) requirements were compared to PM included in licensee PM procedures. Three discrepancies were identified. The manual requires:
(1) yearly overspeed testing, for which no licensee procedure was identified, (2) linkages to be cleaned, lubricated, and inspected quarterly, but the licensee is doing this yearly; and (3) weekly and monthly PMs, for which no licensee procedure was identifie VT1 is also discussed in paragraph f. FSAR Table 3.9B-3a Was Not Current One of the valves (E22*MOV F001) which was selected for qualification document review, from the active equipment list in the FSAR, had to be dropped from the inspection as the valve was no longer considered to belong on the active list. The licensee stated that the valve had been dropped from the list greater than 1 year earlier due to a reevaluation of requirements. This is an open item (8606-03) pending further review by the NRC inspector during a subsequent inspectio _ _ _- _ _ . _ - _ _ _ _ - - -
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7. Vendor Manuals Vendor technical manuals were compared against an interoffice memorandum dated June 6,1978, from J. A. Kirkebo to all responsible, principal, and lead engineers. The subject memorandum identified information that should be contained in all vendor manuals. During the comparison, nine manuals were reviewed and five were found to have anomolies. This will remain an open item (8606-04) pending review by the NRC inspector during a subsequent inspectio . Exit Interviews The inspectors met with the licensee representatives (denoted in paragraph 1) on February 7 and March 7, 1986, and summarized the scope and findings of inspection activities. The senior resident inspector attended these meeting I