ML20137E165

Insp Repts 50-369/85-32 & 50-370/85-29 on 850923-27. Violations Noted:Failure to Follow Procedure When Replacing Tubing Test Tee on Cold Leg Accumulator Level Transmitter

ML20137E165
Person / Time
Site:	Mcguire, McGuire
Issue date:	11/14/1985
From:	Christensen H, Debs B, Moore L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137E140	List: ML20137E135 ML20137E142 ML20137E165
References
50-369-85-32, 50-370-85-29, NUDOCS 8511270212
Download: ML20137E165 (10)

See also: IR 05000369/1985032

Text

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.- g 2Kfoug UNITED STATES

p. fo NUCLEAR REGULATORY COMMISSION

, [ n REGION il '

g  ; 101 MARIETTA STREET, N.W.

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e ATLANTA, GEORGI A 30323 '

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Report Nos.: 50-369/85-32 and 50-370/85-29

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Licensee: Duke Power Company

422 South Church Street [

Charlotte, NC 28242

Docket Nos.:. 50-369 and 50-370 License Nos.: NPF-9 and NPF-17 I

. Facility Name: McGuire 1 and 2

Inspection Conducted: Se tember 23-27, 1985

Inspectors: . . O- M

W. O. Christensen

3 // //2 9[

Dafe Sifned

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_}m llf/ ate Signed

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'L.R.MooreQ

Approved by: N- // /N/h,

B. T.' Debs, Acting Section Chief Datd' Signed

Operational Programs Section

Division of Reactor Safety  ;

SUMMARY

Scope: This ' routine, unannounced inspection entailed 64 inspector-hours on site

in the area of maintenance programs,

Results: One violation with five examples was identified -

Violation ,

50-370/85-29-01; Contrary to 10 CFR 50 Appendix B and Technical Specification , 6.8.1.a. the licensee:

a. Failed to follow procedure when replacing a tubing test tee on a cold leg

accumulator level transmitter, 2NI LT 5110, which required Quality Control

l review.

l b. Failed to retain calibration data sheets and independent verification

! checklist of cold leg accumulator level transmitters. >

L c. Failed to follow calibration procedure for cold leg accumulator level i

l transmitters and initiate a procedure change when using unreviewed reference i

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data ano calibration method for level instrument calibration. l

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d. Used an inadequate procedure to calibrate Unit 2 cold leg accumulators with I

Unit I reference data.

i DD11270212 851119

PDR ADOCK 05000369

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e. Failed to conduct a required functional verification of cold leg

accumulators after completing maintenance.

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REPORT DETAILS

l 1. Persons Contacted

Licensee Employees

• T. L. McConnell, Plant Manager

• A. F. Batts, Quality Assurance

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• R. Branch, Quality Control Supervisor

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• S.'Capp, Planning Engineer

• J. A. Effinger, Quality Assurance

• E. E. Ester,. Project Services

• H. Farr, Instrument and Electrical Supervisor

• D. M. Franks, Quality Assurance

• R. A. Johanson, Performance '

• D. Marquis, Performance Engineer

, *N. McCraw, Compliance

• W. H. McDowell, Licensing, Corporate Office

! *S. McInnis, Compliance

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• M. K. Nazar, Projects

l *D. Rains, Maintenance Superintendent

( *K. W. Recce, Instrument and Electrical Unit 1 Coordinator

l *M. Sample, Integrated Schedule

• D. E. Simmons, Instrument and Electrical Support Engineer

• G. Singletary, Instrument and Electrical Associate Engineer

• C. B. Taylor, Training / Safety

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• J. W. Temple, Maintenance, Corporate Office

l *B. Travis, Operations

• L. E. Weaver, Station Services

• R. B. White, Instrument and Electrical Engineer

Other licensee employees contacted included engineers, technicians,

operators, and mechanics.

NRC Resident Inspectors

• W. T. Orders, Senior Resident Inspector

*R. C. Pierson, Resident Inspector

• H. C. Dance, Projects Section 2A Section Chief, Region II

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• C F. Smith, Reactor Inspector, Region II i

*M. A. Scott, Reactor Inspector, Region II

• Attended exit interview

2. Exit Interview

l The inspection scope and findings were summarized on September 27, 1985,

with those persons indicated in paragraph I above. The inspector described

the areas inspected and discussed in detail the inspection findings. No

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dissenting comments were. received from the licensee. The licensee did not

identify as proprietary any of the materials provided to or reviewed by the

inspectors during this inspection.

3. Corrective Maintenance (62700)

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The inspectors reviewed the licensee's corrective maintenance program to

verify that the program had been established in accordance with regulatory

requirements, industry guides and standards, and Technical Specifications.

The review consisted of reviewing procedures, selected maintenance work

requests, and interviews with various maintenance personnel. McGuire's

Station Directive 4.7, Control of the Maintenance Program, The Maintenance

Management Program Manual and Duke Power's Administration Policy Manual,

. sections 3.3 and 4.6, establish the methods and responsibilities for

managing the initiation, planning, scheduling, execution, status tracking,

and documentation of maintenance work. The inspectors noted the following:

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McGuire's backlog of work request is approximately 3200 requests. Of

this number, 450 require a plant outage to be worked. The trend in

total number of work requests appear to be stable over the past year.

For September, the maintenance department was currently working 609

requests; approximately 1800 were in the planning or pending stage, 616

were new or just received, and 100 work requests were awaiting parts.

McGuire management and Duke corporate maintain a close track of the

work request status. Corporate and upper plant management receive a

monthly status report on maintenance backlogs. The maintenance

planning department receives a weekly computer printout, by planner, of

all work requests and their status from initiation to completion.

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McGuire work request form is divided into nine sections. Section I

identifies the equipment to be worked on, the equipment problem, and

the job priority.Section II delineates the required pre-maintenance

requirements. These are safety considerat '1, health physics involve-

ment, QC involvement, and the determinatior. if the equipment is safety-

related.Section III of the work request is used by the planner to

determine work sequence and job requirements.Section IV is used to

list the material used in the job, and Section V is used by the

maintenance crafts to document all maintenance actions taken with

respect to the job. Section VI, if required, is used for health

physics concerns. Section VII is used for the Quality Assurance

reviews, and Section VIII is used to indicate the func.tional

verification and its documentation. Also, it is the section, used to

specify any retest requirements. Finally,Section IX is used for

documenting the work completion, acceptance, and approval of the

maintenance performed.

It was noted, in general, that in Section V of the work request, the  ;

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crafts personnel were not documenting maintenance activities to the

detail necessary to provide effective feedback for management review or

equipment history evaluation. The individual areas of section V, which

are the equipment failure cause portion and the failure coding system

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portion used to maintain proper data for failure analysis and trend

forecasting, are not being utilized. A review of Section VIII, Retest

and/or Functional Verification section, indicated that for functional

verification tests, the methods section has not been very descriptive,

also the results are not documented in great detail. An example of

this is Work Request 121696 OPS, Investigative and Repair Leaking Line

on Upper Head Injection System. The repair consisted of installing a

temporary modification which replaced a test pressure gage, removed a

leaking relief valve, used the internal relief valve of the pump in the

line, and replaced a fitting in the pipe to stop the leak. The

functional test method stated, " observed location for installation and

did same." The results were documented " sat." From this functional

test description and test results, it can not be determined what was

functionally verified. Maintenance Management Procedure 4.1,

Maintenance Activities Associated with the Functional Verification /

Surveillance Retest Program, gives guidance on the type of functional

verification required and how this verification should be documented.

Additionally, Station Directive 3.2.1, Identi fying , Scheduling and

Performance of Plant Testing, establishes the program and responsi-

bilities for insuring components receive a functional verification or

retest following maintenance. The procedure states that a functional

verification shall be performed on QA Conditions 1, 2, 3, and 4

components, security systems, and Technical Specification related

components following maintenance and should be performed on other major

components of non-safety-related support systems. The inspector noted

that functional verification of non-safety-related equipment is usually

not required by the maintenance planners, as indicated by marking the

work request section II as "NO." An example of where a functional test

should have been required was Work Request 123466 OPS to investigate

possibility of damage to IC condenser circulation water pump due to

receiving very high thrust bearing temperature alarms. The corrective

action was to replace oil in the upper and lower motor oil pots. Upon

completion of the oil change, no functional verification was performed

to determine if the oil change corrected the high thrust bearing

temperatures.

In reviewing numerous work requests, the inspector noted that Work

Request 123686 OPS had several deficiencies. Work Request 123686 OPS

concerns the investigation and repair of cold leg accumulator level

loops. This work request required the instrument technicians to vent

all eight cold leg accumulator level transmitters and, if needed,

calibrate the transmitters to ensure the indicators in the control room

agree with the calibrated transmitters. Additionally, if the

technician was required to perform any instrument line tubing work, he

was required to contact Quality Control (QC). The maintenance planner

designated the work request as non-safety-related and quality control

review was not required. A designation of non-safety-related was based

on a review of the instrumentation manual, which classified the level

transmitter as being safety class for the impulse lines to the

instrument, but the instrument itself performed no safety-related

function. McGuire's quality standards manual for structures, systems,

and components defines safety-related as those structures, system <, and

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components which prevent or mitigate the consequences of postulated

accidents which could cause undue risk to the health and safety of the

public. Additionally, the quality standards manual classifies

instrument piping connected to a QA Condition 1 (nuclear safety-

related) systems as QA Condition 1 components. However, the connected

instrument is not considered safety-related unless it performs a

necessary safety function.

10 CFR 50, Appendix B, Criterion V, states; " Activities affecting

quality shall be prescribed by documented instructions, procedures, or

drawings, of a type appropriate to the circumstances and shall be

accomplished in accordance with these instructions, procedures, or

drawings. Instructions, procedures, or drawings shall include

appropriate quantitative or qualitative acceptance criteria for

determining that important activities have been satisfactorily

accomplished."

The approved Quality Assurance Program states, " Duke Power has

established and implemented a quality assurance program which conforms

to the criteria established in Appendix B to 10 CFR 50." Section 17.2.5

of Duke's Quality Assurance Program states, "The basic, written

instructions and procedures for operation activities affecting quality

are contained in the Nuclear Production Department's, Administrative

Policy Manual for Nuclear Stations. It is required that personnel

implement this manual as it pertains to the performance of their

activities."

Administrative Policy Manual, procedure (APM) 4.2, Administrative

Instructions For Permanent Station Procedures, section 4.2.6, states,

'" Activities shall be conducted in accordance with the provisions of the

applicable procedure."

McGuire's Technical Specification 6.8.1.a, states; " Written procedures

shall be established, implemented, and maintained covering the

activities of the applicable procedures recommended in Appendix A of

Regulatory Guide 1.33, Revision 2, February 1978."

Regulatory Guide 1.33, revision 2, February 1978, Appendix A, states,

that the following are typical safety-related activities that should be

covered by written procedures:

a. Administrative Procedures on (a) procedure adherence and temporary

change method, (b) procedure review and approval, and (c) log

entries, record retention, and review procedures.

b. Procedures for Performing Maintenance. Maintenance that can

affect the performance of safety-related equipment should be

properly preplanned and performed in accordance with written

procedures, documented instructions, or drawings appropriate to

the circumstances.

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Wor'k Request 123686 OPS, had the following deficiencies:

The technician found a tubing test tee leak on cold leg

accumulator 'D'. level transmitter, 2NI LT 5110. The test tee was

replaced,-but quality control was not contacted as required by the

work instruction in section III of the work request.Section III,

stated, " Note: Any tubing work contact QC Prior!"

Accumulator Tank ievel drawing, MC-2499-N18.01, states that

fittings, tubings, and valves designated on' this detail by

classification (4s) of the fitting classification list are safety

class. Substitutes from other classifications are not permitted.

The tubing test tee is within the (4s) classification boundary.

Mechanical Instrumentation and Controls Instrument Standards,

drawing ICS-A-11, states that when a safety class' materials'

identification flag is shown at an instrument, the impulse line

between the isolation or manifold valve and the instrument is

excluded from ASME section III code requirements; however, the

appropriate safety class fittings and tubing shall be used.

The inspector contacted Quality Control (QC) instrument section

and an instrument QC inspector stated that the replaced test tee

should have received QC inspection and the inspection would have

consisted of a verification of proper material and a sight

inspection of the test tee replacement. The QC inspector also

stated that a non-conforming items report would be generated.

Additionally, Administrative Policy Manual 3.3, Maintenance,

section 3.3.2.3(b) which states that for maintenance activity which

affects the pressure boundary of system or components classified

as ASME Boiler and Pressure Vessel code class 1, 2, or 3, a code

authorized inspector shall be provided an opportunity to review

the proposed activity prior to the beginning of work if required.

Contrary to the above, QC was not informed or provided an

opportunity to review the test tee replacement prior to repair as

required by the work request, section III. The inspector informed

the -licensee that this was an example of failure to follow

procedures (VIO 370/85-29-01). The licensee stated that the note

in section III of the work request pertained to entire tube

replacement work,'and not to a test tee fitting replacement.

Of the eight level transmitters - calibrated, only five of the

calibration data sheets were in the work package. A review of

section V of the work package indicates instrument 2NILT 5080 was

calibrated, but instruments 2NILT5100 and 2NILT5110 have no

documentation at all. The inspector was informed by the

instrumentation supervisar that both instruments were calibrated.

t- Additionally, the independent verification checklist for level

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transmitters 2NILT 5060 and 2NILT 5070, which were calibrated on

April 24, 1985, was missing.

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Station Directive 2.1.1., Control of Master File Documents, states

in part, that document retention requirements are.six (6) years or

service life - whichever is greater for; copies of completed work

requests and equipment histories for measuring and test devices  :

- and installed process instrumentation.

Contrary to station directive 2.1.1, the licensee failed to retain

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the calibration data sheets and an independent - verification

checklist for work request 123686 OPS. The licensee was informed

that the .above was a second example of failure to follow

procedures.

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The calibration on April 24, 1985, of . cold leg accumulator

transmitters 2NILT 5060 and 2NILT 5070 were not performed as

specified by procedure, IP/0/A/3214/04, Calibration Procedure for

Rosemount Model 1152 Transmitters, step 10.1.7, which states,

" apply input pressures at approximately 0, 25, 50, 75 and 100% of

input range specified for this transmitter." .The only applied

input pressure to the transmitter was at input ranges of 0% and

100%. The licensee. informed the inspector that a different method

of ' calibration was performed on the instruments. McGuire's-

- Station-Support Detachment, North, took a new elevation survey of -

the level transmitters as referenced to the cold leg accumulator

taps. - This- data was used by the instrumentation group to place

elevation reference marks on the wall next to the transmitters for

the 0% and 100% level reference. A tygon tube was. connected to the

level transmitter to act as the water column-pressure source. The

instrument technician then varied the height of the tube from the

0% reference point to the 100% reference point to calibrate the

transmitters' end points. The inspector expressed concern over

this method of calibration because no approved procedure or

procedure change was initiated, and the reference data used by the

technician was not properly reviewed or approved for use.

Station Directive 4.2.1, Handling of. Station Procedures, states in-

. par',, that this directive applies to all, both safety-related and .

non-safety-related, station procedures with each being processed '

similarly except as noted. If any deviation from the method and i

steps specified in procedures is necessary, a procedure change

shall be initiated. It is the responsibility of each person using

the procedure to ensure the procedure is followed or appropriate

procedure changes are initiated and approved prior to using the

procedures.

Contrary to Station Directive 4.2.1, the licensee failed to follow

IP/0/A/3214/04 or initiate an approved procedure change before 1

using new unreviewed reference data. The licensee was informed

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that the above.is the third example of a procedural violation.

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A review of Work Request 123686 OPS, section V, the maintenance

action taken, indicated that the technician performing the

calibrations of the transmitters discovered that the unit 2 cold

leg accumulator transmitters were calibrated with incorrect input

data from procedure IP/0/B/3000/03, revision 15, Accumulator Tank

Level Calibration. The incorrect input data was used

February 1985 when performing the technical specification required

18 month calibration of the cold leg accumulator level trans-

mitters. The inspector was concerned that the incorrect input

reference data could be approved in a procedure change and used,

and not be detected by the procedure review and approval process

or the review process associated with the completed work request.

Contrary to 10 CFR 50 Appendix B, Criterion V, the licensee

procedure IP/0/B/3000/03, revision 15, was inadequate in that the

licensee calibrated unit 2 cold leg accumulator level transmitters

with unit one reference data. The licensee was informed that this

is the fourth example of violation (370/85-29-01).

The inspector examined Work Request 123686 OPS, Investigate and

Repair Cold Leg Accumulator Level Loops, and Work Requests 023345PM

through 023352PM, Perform PM/PT on NI Accumulator Level Instruments.

The planner failed to require and the technician failed t) perform

functional verification of transmitters as required by Station

Directive 3.2.1, Identifying, Scheduling and Performance of Plant

Testing. Station Directive 3.2.1, states that a functional

verification shall be performed on QA Conditions 1, 2, 3, and 4,

security systems and Technical Specification related com?onents

following maintenance. Cold leg accumulator instrumentat ion is

required by Technical Specification 3.5.1.1.e, which states that

each cold leg injection accumulator shall be operable with a

water level and pressure channel operable.

The licensee was informed that the failure to conduct cold leg

accumulator level transmitter functional verification is the fifth

example of failure to follow procedure. (VIO 370/85-29-01).

With the exception of these examples of failure to follow procedures, the

corrective maintenance program, as implemented by McGuire station directives

and maintenance management procedures appear to be procedurally adequate in

meeting regulatory requirements, industry guides and standards and McGuire's

Technical Specifications.

4. Preventive Maintenance Program (PM)

The inspector conducted a review of the licensee's implemented preventive

maintenance program (PM). This review consisted of reviewing the licensee's

administrative, quality, and maintenance department procedures and related

training and M&TE documentation required for maintenance accomplishment.

Included also were interviews of individuals responsible for planning,

scheduling, tracking, and developing PMs.

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Guidance for the McGuire Preventive' Maintenance- program is proiided by

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. Maintenance Management Procedure 5.1 (Rev 1). PM scheduling is accomplished

via this guidance by use of computer originated printouts displaying current

maintenance requirements on a biweekly basis. The PM coordinator is

responsible for. proper distribution and tracking of maintenance tasks.

Review of the Management Information System (MIS) monthly data report for

August 1985 revealed a continued reduction in the backlog of outstanding PM

work re' quests indicative of successful PM scheduling implementation.

The inspector reviewed a number of vendor technical manuals for various ,

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plant components to determine the adequacy. of PM procedures to meet vendor

suggested routine maintenance. Generic and specific procedures reviewed met

4 or exceeded vendor requirements. A lubrication and vibration toned analysis

program has been established to monitor and analyze plant operating

equipment.

j Completed maintenance packages were reviewed to verify adequacy of training

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and validity of test equipment utilized to perform mr.intenance. Except for

two isolated cases, documentation of personnel t-aining was adequate.

Implementation of the Employee Training Qualification System (ETQS) program

by the licensee should eliminate such exceptions in the future.

Additionally, qualification of maintenance and test equipment (M&TE) used to

perform maintenance tasks was verified. M&TE selected from completed

maintenance was clearly traceable to national standards and properly

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controlled. Selected safety and Technical Specification related process

instrumentation was also verified to be controlled by an adequate

calibration control program and traceable to national standards.

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The PM Program, as implemented at McGuire, appears to be adequate in meeting

the'.-requirements and commitments made in Technical Specifications,

applicable regulatory guides and standards.

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