IR 05000277/1993029

Insp Repts 50-277/93-29 & 50-278/93-29 on 931012-15.No Violations Noted.Major Areas Inspected:Review of Pims Interface W/Maintenance Including Work Order Development & Maintenance trending,Unit-3 Arts/Mell Mod Training

ML20059J698
Person / Time
Site:	Peach Bottom
Issue date:	11/01/1993
From:	Conte R, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059J694	List: IR 05000277/1993029 ML20059J690
References
50-277-93-29, 50-278-93-29, NUDOCS 9311150017
Download: ML20059J698 (3)

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U.S. NUCLEAR REGULATORY COMMISSION;

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REPORT NOS: 50-277/93-29 50-278/93-29 -;

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DOCKET NOS: 50-277; 50-278

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LICENSE NOS: DPR-44; DPR-56 ,

FACILITY LICENSEE: Philadelphia Electric Company j Nuclear Group Headquarters

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Correspondence Control Desk P. O. Box 195 Wayne, Pennsylvania 19087-0195 FACILITY NAME: Peach Bottom Units Nos. 2 and 3 .

s INSPECTION AT: Delta, Pennsylvania INSPECTION CONDUCTED: October 12-15, 1993 .

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INSPECTOR: Y)

D. Florek, Sr. Operations Engineer Dite' l'

BWR Section, Operations Branch Division of Reactor Safety APPROVED BY: 4 ve

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Richard Conte, Chief Date BWR Section, Operations Branch Division of Reactor Safet .

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9311150017 931104 .I PDR ADOCK 05000277 '

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Insoection Summary: Inspection on October 12-15,1993 (Inspection Report Nos. 50-277/

93-29 and 50-278/93-29) ,

Areas Insoccted: An announced safety inspection was performed to review areas important i to the health and safety of the public. The inspection included a' review of the Plant :

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Information Management System (PIMS) interface with maintenance including work order -

development and maintenance trending, Unit-3 " ARTS /MELL" modification training and l licensee actions on previous inspection finding Results: PIMS interfaces effectively with maintenance activities. _ The computer-based work <

order system with interfacing holds applied assures that all interfacing organizations complete :

their necessary work before the actual maintenance work can be started. The historical file capability of the PIMS allows the work order development personnel to have quick access to

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prior similar maintenance activities to have consistent maintenance practices. The hold capability of the PIMS module and automatic determination of QC notification assures that ,

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the QC organization reviews the maintenance work for inspection activities. No unacceptable conditions were identifie i The inspector concluded that the facility licensee is using the historical capability of the PIMS system for trending maintenance failures. However, the facility licensee practice is

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currently different than that identified in the facility procedures. The facility licensee is #

assessing their current practices and procedures for trending maintenance dat " ARTS /MELL" lessons p'ans are being developed for operation with an expanded core power / flow map. " ARTS /MELL" training will be provided to licensed operators prier to assuming shift duties on Unit 3 when Unit-3 starts up after the outag l

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Unresolved Item 93-20-01 regarding diesel generator operability during refueling is closed based on the license current design basis, the administrative controls in place to control removing a diesel generator from service and the prior commitments to improve technical ,

specifications. Unresolved Item 92-32-01 regarding component misposition events is updated and remains open since the facility licensee is still implementing ~many of the long-term corrective actions and monitoring and evaluating the effectiveness of those corrective actions i already implemente .

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DETAILS ' l INTRODUCTION-The purpose of this regional initiative safety inspection was to review the facility licensee's ,

Plant Information Management System (PIMS) interface with maintenance activities._ The PIMS is the principle tool used by the facility licensee to request, develop, control and trend ,

maintenance activities. In addition, the inspection reviewed the facility licensee activities to -

provide training to licensed operators on the Unit-3 modification identified as . ,

" ARTS /MELL." The inspector also reviewed the facility licensee efforts in monitoring and reducing the number of " component misposition events." The inspector also reviewed prior -

facility licensee actions on inspection finding Inspection Procedure Numbers 62700, 41500, and 92701 are the inspection procedure '

numbers used during the conduct of this inspectio .0 PIMS MAINTENANCE INTERFACE

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Scope Proper maintenance is important to the safe operation of the facility. To verify plant safety, an inspection was conducted to determine if the facility licensee's PIMS interface with maintenance resulted in acceptaHe controls of the maintenance activit Attachment 1 provides a list of documentation reviewed during this inspection. The - ,

inspector also contacted the Manager of Maintenance Planning, the Unit 2 Maintenance Coordinator, a Maintenance Planner Foreman, a Maintenance Planner, a Shift Maintenance

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Foreman, a Maintenance Worker, a Reactor Operator, a Health Physics Engineer, and a Quality Control Inspectoi to assess the knowledge and use of the PIMS. The inspector also selected equipment in the control room with deficiency tags and verified that the PIMS

accurately recorded the equipment and maintenance statu The inspector also observed the daily maintenance / operations interface meeting and observed maintenance in progress on the containment chiller syste .

Findings The Plant Information Management System (PIMS) is a PECo corporate-wide, computer-based program that contains several modules for various activities. One of the modules ,

available in the PIMS is the control of maintenance activitie The PIMS controls maintenance activities by allowing any individual to input an action

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request (A/R) for maintenance activities. The maintenance activity can either be corrective or preventative. Once an A/R is input into the computer, the A/R is directed by the ,

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computer to the Unit Maintenance Coordinator. Immediately following the daily maintenance / operations interface meeting, the inspector observed the Unit Maintenance

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Coordinator and the onshift senior reactor supervision review the new corrective maintenance -

A/R's for acceptance of the A/R for the type and priority of the maintenance to be performed and for the assignment of the preliminary schedule for completion of the maintenance.' The !

priority considers technical specification limiting conditions for operations and the need for cont *nued plant operation. Once the A/R is reviewed and authorized to proceed, the A/R is - !'

forwarded to maintenance planning where the maintenance planner converts the A/R into a work orde '

The work order establishes the procedure *o be used, scaffolding needs, the parts and material needs, the clearance and tagging request, the RWP request, the post-maintenance .;

testing needs and the QC inspection needs. The QC interface is automatically controlled by-whether the equipment to be maintained is either on the "Q" list, environmentally qualified ;

or included as part of the Section XI Inservice Inspection program. Once the maintenance planner completes the work order the computer automatically sends the requests to the >

identified organizations. PIMS places holds on permitting the work to be started until all the interfacing organizations remove their assigned hold ;

The warehouse orders the requested parts if necessary. The health physics group prepares -

the RWP based on the maintenance needs. Because the system is computer-based, the HP engineer can refer to either current or prior completed RWPs for the HP restrictions on the work. When the RWP has been created a computer hold is removed that acknowledges that  ;

the RWP portion of the maintenance request has been completed. The clearance and tagging activity in PIMS is controlled in a manner similar to the RWP reques QC is automatically notified of maintenance activities as stated above. In addition, if the ;

maintenance planner considers QC involvement is appropriate for maintenance activities other than stated, above a QC request can be included in the work order. The QC inspectors are assigned to review the PIMS maintenance module. When a work order is transmitted to QC, ,

QC must provide a response to permit the work order to be processed further. The QC can l'

either determine that no QC inspections will be performed or perform QC inspection When the QC inspections are to be performed, the PIMS interface requires a QC plan to be developed before the work order can be processed further. Absent the QC plan, PIMS will place a hold on the wor ,

When all the holds are removed, the work can start when authorized by the on-shift supervision. The maintenance foremen update the work order status daily. When the work order is complete, the post-maintenance testing and QC inspection are complete, the -!

clearance and tagging removed, and the equipment returned to service the work order history _ j

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is stored in the compu+er historical file for future us i The historical file of the work order is for maintenance trending. This is discussed further in i the next section of this repor :

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The inspector determined that all the persons interviewed during this inspection were knowledgeable of the PIMS process. RWP, QC, and clearance and tagging development are being completed ahead of the schedule for the maintenance. The control room deficiency

- tags in the control room agreed with the A/R assigned in the PIMS. The daily maintenance / operations interface meetings are effective in controlling, scheduling and implementing maintenance activities with PIMS. The maintenance activity observed was performed in accordance with the PIMS work order proces Conclusions PIMS interfaces effectively with the maintenance activities. The computer-based work order system, with interfacing holds applied, assures that all interfacing organizations complete their necessary work before the actual maintenance work can be started. The historical file ;

capability of the PIMS allows the work order development personnel to have quick access to l prior similar maintenance activities to have consistent maintenance practices. The hold l

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capability of the PIMS module and automatic determination of QC notification assures that the QC organization reviews the maintenance work for inspection activities. No unacceptable l

conditions were identified in this portion of the inspectio .0 MALNTENANCE TRENDING .

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The inspector reviewed the use of the PIMS historical file for the use of maintenance trending. The inspector reviewed the maintenance trending performed with the site i

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engineering failure trending coordinator. The inspector also discussed with the HPCI system manager the monthly review of equipment maintenanc l Findings l

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The facility maintenance trending activities are controlled in procedure AG-26-17

" Equipment Failure Trending." The program consists of component level trending on a daily ;

basis, component type and manufacture failure trending on a quarterly basis and a system !

manager monthly review of the maintenance work performed on the assigned system the l

.I previous mont The component level trending on a daily basis is backlogged about one month. This log provides an analysis of new corrective maintenance action requests on the previous day that have 2 or more additional A/Rs generated within the past 18 months. The backlog is due to other assigned work activities and the number of known repeat maintenance tasks that clutter up the daily reports. One of the purposes of the daily trending is to provide to the planners and troubleshooters timely information in the determination of the maintenance for the piece i

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of equipment. Due to the backlog, the timely feedback loop is not effective. The facility licensee recognizes the backlog and is assessing the need for the currently defined daily trending activit The HPCI system manager indicated that he had not recently received monthly work performed information on the HPCI system and, as such, has not recently completed the -

system manager trending review. However, based on the prior problems with the HPCI system identified from the historical trending file, a HPCI improvement plan has been developed by the facility licensee. Procedure and hardware improvements were made to the Unit 3 HPCI during the Unit 3 refuel outage. The Unit 2 HPCI improvements are scheduled during the next Unit 2 refuel outage. -In addition the facility licensee management monitors and reviews HPCI availability on a periodic basi Conclusions The inspector concluded that the facility licensee is using the historical capability of the PIMS system for trending maintenance failures. However, the facility licensee practice is currently different than that identified in the facility procedures. The facility licensee is assessing their current practices and procedures for trending maintenance dat .0 ARTS /MELL MODIFICATION TRAINING The inspector reviewed the status of the facility licensee training being provided to the licensed operators in the average power range monitor, rod block monitor, technical specification / maximum extended load line limit (ARTS /MELL) modification installed on Unit 3 during the outage. Unit 2 will be modified during the next Unit-2 refueling outag ARTS /MELL is a modification that will result in an expanded power / flow map. The NRC approved license amendment 184 on this modification on September 14,1993. The modification will improve achieving rated power and allow rated power at less than rated recirculation flow during the fuel cycle. The modification affects the average power range monitor (APRM) ar.d rod block monitor (RBM) and technical specification The facility licensee has completed the modification but the procedures are not yet completed. The lesson plan for the training is still being developed pending completion of the procedures. A four-hour, comprehensive training session will be included in the requalification cycle starting October 25,1993. Based on the projected startup of Unit 3, some of the operators will not receive the comprehensive training prior to Unit 3 startu These operators will receive a two hour overview training session prior to assuming shift on Unit-3 when Unit-3 starts up and the comprehensive training during their normal requalification training week. The inspector considered this training approach acceptabl d W .

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, FACILITY LICENSEE ACTIONS ON PREVIOUS INSPECTION FINDINGS - ,

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, Unresolved items (URIs) are matters about which more information is required to. ascertain; j

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whether they are acceptable items or violations. Unresolved items previously identified in inspection reports 50-277/93-20, 50-278/93-20, and 50-277/92-32, 50-278/92-32 were .]

reviewed for closure by the inspecto i

Diesel Generator Operability During Refueling '

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Closed (Unresolved item 277/93-20-01 and 278/93-204)l). This item deals with the technical specification requirements for diesel generators during refueling. The facilit ~

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licensee assessed the FSAR requirements for diesel generators during refueling.- The design l

basis refueling accident in the FSAR does not require diesel generators to respond to the event. The current technical specification requirements for diesel generator operability, j

during refueling are based on the need for emergency core cooling and are consistent with the FSAR. In the improved technical specification program effort that the facility is '}

undertaking, the facility has previously committed to include technical specification j requirements for the diesel generators during refueling. The technical specifications will be !

based on the BWR owners group shutdown cooling risk analysis to maintain at least one ]

diesel generator operable. The facility expects to implement the improved technical specifications in late 1995 or early 1996. The facility licensee currently has in place !

administrative controls that control removing a diesel generator from service. These controls y

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include an assessment of the impact on loss of a diesel. Since the diesel generators are shared by both units, the operating unit technical specification requirements are boundin q In conclusion,- based on the license current design basis, the administrative controls in place'. ;

and the prior commitments for improving diesel generator technical specifications during ,

refueling, this item is close j

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Component Misposition Events

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Open Unresolved Item 277/92-32-01 and 278/92-32-01). This item deals with the specific '

long term correction actions related to the component misposition event resulting in the emergency service water (ESW) system outside the Appendix R Design Basis and review of 1 the broader corrective actions addressing the general problem of component misposition i event i

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The inspector reviewed the status of the long-term specific corrective action program plans .j related to the component misposition event of the ESW system. The facility licensee is still j implementing many of the long-term corrective actions identified in response to the even ;

The inspector noted that the self check program was initiated over the summer. The facility l licensee is currently monitoring and evaluating the effectiveness of the progra j a

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The inspector was also interested in the facility licensee establishment of a policy that l specifies the group or groups that are permitted to operate equipment at Peach Bottom. The

inspector was concerned about this activity, which has not yet been completed, since maintenance personnel are currently permitted to opemte equipment within a clearance and ,

tagging boundary. This has the potential to result in a component misposition event when the clearance and tags are removed. In discussions with operations personnel and review of i the component misposition events reports, the inspector concluded that maintenance personnel operation of equipment is not a major contributor to the component misposition events at Peach Botto .

The inspector reviewed the facility licensee actions regarding assessing Peach Bottom component misposition events. The facility licensee plant management uses component misposition events as a performance indicator. The independent Nuclear Review Board also periodically reviews the component misposition events performance indicator. The facility l licensee is trying to implement programs to reduce the number of component misposition events. The facility licensee had 56 events in 1991,57 events in 1992, and currently have 50 events to date in 199 The facility licensee is evaluating the effectiveness of the programs that they have initiated in response to the misposition events. The facility licensee projects that there may be more misposition events in 1993 than in prior years due to coming out of the Unit 3 outage. The facility licensee considers that the recently-initiated self-check program will help to reduce component misposition events, but monitoring of the effectiveness of the program is ongoin '

The facility licensee representative acknowledged that the prior corrective actions may not be as effective as initially thought, but indicated that senior facility licensee plant management wants to reduce the number of misposition events and will continue to pursue effective corrective actions to reduce the number of events. The inspector noted that, even though the number of misposition events have increased, the number of misposition events that are considered to be significant have decrease .

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In conclusion, unresolved item 92-32-01 regarding component misposition events is updated and remains open since the facility licensee is still implementing many of the long-term corrective actions and monitoring and evaluating the effectiveness of those corrective actions already implemente . EXIT MEETING ,

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An exit meeting was conducted on October 15, 1993. Personnel in attendance are listed below. The NRC presented the inspection findings as described in this report. The facility licensee representatives acknowledged the NRC finding ..

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Philadelphia Electric Company G. Edwards, Plant Manager G. Gellerich, Sr. Operations Manager

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M. Hammond, Site Engineering

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i D. IxQuia, Director Maintenance ,

S. Mannix, Operations Support Manager D. Schra, ISEG/NQA R. Smith, Regulatory A. Trapuzzano, Nuclear Quality Assurance M. Wolfe, Maintenance Supervisor U. S. Nuclear Regulatory Commission i

F. Bonnett, Resident Inspector

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D. Florek, Sr. Operations Engineer

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' Attachment: Documentation Review

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A'ITACIIMENT I DOCUMENTATION REVIEW Procedures  ;

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AG-26.11, " Corrective Maintenance Action Requests," Revision 6 dated August 5,1993 AG-26.12, "PIM Work Order Processing," Revision 6 dated September 3,1993 AG-26.13, " Work Package Planning," Revision 5 dated September 3,1993 ,

AG-26.14, " Work Performance Using PIM," Revision 5 dated September 3,1993 AG-26-17, " Equipment Failure Trending," Revision 0 dated December 27,1992 NQA-4-SIB, "QV Planning of the PIMS Work Order," Revision 5 dated May 15, 1993

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NQA-4-S1C, "QCV Plan Generation," Revision 1 dated September 14, 1992 NQA-4-SlD, " Performance Documentation of QV Documentation of QV Verification in PIMS," Revision 2 dated May 15, 1993 NQA-4-SIE, "PIMS Work Order Activity Revision and Closure," Revision 1 dated '

September 14, 1992

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