ML20137Y514
| ML20137Y514 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/02/1996 |
| From: | Holland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Christensen H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20137Y003 | List: |
| References | |
| FOIA-96-485 NUDOCS 9704230107 | |
| Download: ML20137Y514 (20) | |
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! October 2, 1996 MEMORANDUM i From: William E. Holland. Team Leader St. Lucie MR Baseline Inspection p To: Harold 0. Christensen, Chief, Maintenance Branch, DRS 3
Subject:
MAINTENANCE RULE ENFORCEMENT PANEL l In accordance with Regional Office Instruction No. 0924. I submit the proposed
! violations which were identified during a Maintenance Rule Baseline inspection ;
j conducted at the St. Lucie plant on September 16 - 20. 1996. I will be available t
- to discuss the proposed violations when the required panel is convened. Excerpts from Draft Inspection Report 50-335, 389/96-13 are included to. support the
- proposed NOVs.
b The initial perspective I have about the' message we need to send this licensee l .is:
1 i BACKGROUND l Preparations for the Maintenance Rule did not start in earnest until after an
- independent assessment of program implementation was conducted in December 1995.
1 The assessment concluded, in part, that the program did not meet the expectations
- of the Rule and related guidance. At that time many activities had to be i readdressed including: performance criteria, reexamination of historical SSC :
3erformance was required, monitoring and goal setting was not well defined, etc. :
Essentially, the licensee started over in preparation of a program for the Rule. !
l However. during the next six months, other priorities occupied the time of 4
critical personnel (system engineer owners) to prepare for the rule. The program i development was essentially implemented during this period by a Maintenance Rule l Administrator (Assigned in January 1996) and the licensee's PRA expert. During 4
this time. the licensee reorganized to increase the system engineering staffing j from 6 to approximately 20 persons. A licensee audit of the program conducted in July 1996, concluded the program was in place and satisfied rule requirements.
!, However, enhancements were necessary and a lack of program elements to evaluate i the overall effect of safety functions when removing equipment from service needed immediate attention. The licensee initiated actions in these areas to put i a matrix in place for taking SSCs out of service, and enhanced program areas with guidelines by the end of August 1996. The audit also stated that the speed at which the program was implemented resulted in weaknesses in integration of
- Maintenance Rule processes in the plant daily routine. This inspection verified and validated this statement.
l MESSAGE The violations represent weaknesses in implementation of the licensee's program for the Maintenance Rule. They appear to be the result of late program implementation, coupled with reorganization in the system engineering area. Many of the engineers are new to their jobs and have not had time to fully understand their systems and requirements for the rule. Management needs to concentrate on the rule implementation and provide the necessary extra training / oversight to improve program implementation.
I 97o4230107 970417 PDR FOIA BINDER 9,6-485 PDR ,.
DRAFT NUTICE OF VIOLATION DRAFT Florida Power & Light Company Docket Nos. 50-335 and 50-389 .
St. Lucie Units 1 and 2 License Nos. DPR-67 and NPF-16 During an NRC inspection conducted on September 16 through 20. 1996. violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions." (60 FR 34381: June 30.
1995/NUREG 1600). the violations are listed below:
A. 10 CFR 50.65 (b) establish the scoping criteria for selection of safety related and non-safety related structures, systems, or components to be included within the Maintenance Rule program. Scoping criteria includes safety-related structures, systems, or components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the 10 CFR part 100 guidelines; and non-safety related structures, systems, or components that are relied upon to mitigate accidents or transients or are used in the plant emergency operating procedures, or whose failure could prevent safety-related structures. systems, and components from fulfilling their safety-related function. or whose failure could cause a reactor scram or actuation of a safety-related system.
St. Lucie Ad'ministrative Procedure. ADM-17.08. IMPLEMENTATION OF 10 CFR ,
50.65. THE MAINTENANCE RULE. Revision 7. implemented the requirements of l 10 CFR 50.65. Appendix B of ADM-17.08 identified those systems and ,
components within the scope of the rule Contrary to the above. I As of September 20. 1996. the licensee had not included all systems and components within the scope of the rule as required. The following ,
systems and components were not included in the scope of the program:
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Post Accident Sampling System - This non-safety related system was not included in Appendix B of ADM 17.08 even though it is used to mitigate the consequences of accidents and is in the licensee's Emergency Operating Procedures (E0P-03. LOSS OF COOLANT ACCIDENT &
E0P-04. STEAM GENERATOR TUBE RUPTURE).
Communications System - This non-safety related system was not included in Appendix B of ADM 17.08 even though it is relied upon to mitigate accidents or transients. and used in the performance of all Off-Normal Procedures and Emergency Operating Procedures.
Unit 1 Service Air System - This non-safety related system was not included on Appendix B of ADM 17.08 even though its failure could prevent safety-related systems or comoonents from fulfilling their safety-related function. Failure of this system which was in use on July 13,1996. would have resulted in the failure of the safety-related low pressure safety injection system operating in the
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i shutdown cooling Mode to maintain reactor coolant system temperature within required limits.
Main Steamline Radiation Monitors - These non-safety related radiation-monitors for Units 1 and 2 were not included in Appendix B of ADM 17.08 even though they are used to mitigate accidents, and are used in Emergency Operating Procedures (E0P-04, STEAM GENERATOR TUBE RUPTURE) as an indication that a steam' generator tube rupture has occurred.
This is a Severity level IV violation (Supplement I) 1 l
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B. 10 CFR 50.65-(a)(1) requires, in part, that each holder of an operating license shall monitor the performance or condition of structures, systems.
or components against licensee established goals. Such goals shall be established commensurate with safety.
Contrary to the above.
- 1. As of September 20, 1996, the licensee had failed to establish reliability goals or performance criteria commensurate with safety for risk significant structures, systems. or components for the-following systems:
Chemical and Volume Control System High Pressure Safety Injection System Low Pressure Safety Injection System Safety Injection Tanks Main Steam System
- Main Feedwater System Auxiliary Feedwater System Component Cooling Water System Instrument Air System Intermediate Cooling Water System Reactor Protection System Electrical' Distribution System These systems had been modeled in the licensee's risk determining analysis, with a reliability goal of less than or equal to 2 maintenance preventable functional failures per 18 months. In establishing these goals, the licensee failed to demonstrate
-performance criteria were established commensurate with the critical assumptions used in the licensee's risk determinating analysis. As such, the licensee's goals for reliability had not been established in a manner commensurate with safety.
- 2. As of September 20, 1996, the licensee had failed to establish adequate goals or performance criteria commensurate with safety for risk significant structures, systems, or components -in that the condensate cross-tie valves between Unit 1 and Unit 2 which were designated as risk significant by the licensee, did not include availability goals, or reliability goals consistent with the critical assumptions used in the licensee's risk determining analysis.
This is a severity level IV violation (Supplement 1)
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! C. 10 CFR 50.65 (a)(1) and (a)(2) specify requirements for goal setting and monitoring, and -preventative maintenance respectively, for structures.
. systems, and components within the scope of the Maintenance Rule.
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St. Lucie Administrative Procedure. ADM-17.08. IMPLEMENTATION OF 10 CFR
.50.65. THE MAINTENANCE RULE. Revision 7. established procedure for-
- implementation of the requirements of 10 CFR 50.65 (a)(1) and (a)(2).
j- 1. ~ ADM 17.08, paragraph 7.8.4 required that cause determinations shall consider any generic implications for structures, systems and components other than the one being evaluated.
[ 2. ADM 17.08, paragraph 7.6.4 required that performance monitoring be i accomplished by tracking specific (SSC Level) and/or Plant Level Performance Criteria and repetitive maintenance preventable
- functional failures. Paragraph 7.11.2. A requires this information l be reported in the licensee's Maintenance Rule Quarterly Reports.
i 3. ADM 17.08. paragraph 4.4.3 stated " System owners are responsible for
! monitoring systems, structures and components for compliance to performance criteria." Also. Appendix B of ADM 17.08 identified the i Chemical and Volume Control and Containment Spray Systems as risk 1
significant with specific availability performance criteria at the train level.
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- 4. ADM 17.08 paragraph 4.4.4 states " System owners are responsible for
- identifying potential maintenance preventable functional failures
- and bringing them to the attention of. Management and the Maintenance L Rule Administrator via the Condition Report Process."
Contrary to the above.
- 1. The generic implications of the failure of a temperature control valve in the Turbine Cooling Water System, which taused a' Unit 2 manual reactor trip on June 6.1996, were not considered for similar valves in other plant systems. -
- 2. Work Orders 95007753-01 and 95007984-01 performed preventive ,
maintenance on the 4.16 KV Station Blackout Crosstie Breakers, and '
no unavailability of these breakers was trended 'against the unavailability performance criteria in the licensee's Maintenance Rule Quarterly Report dated July 9.1996.
Work Orders 95021809-01 and 95023498-01 re3orted re)etitive maintenance preventable functional failures for t1e 4.16 KV 3reakers for the pressurizer heater electrical supply which were not shown in the licensee's Maintenance Rule Quarterly Report dated July 9.1996.
- 3. The Chemical and Volume Control System and Containment Spray System owners were not adequately monitoring their systems and components for compliance to performance criteria since the unavailability hours recorded did not include:
Five hours six minutes on July 10 when the 2A charging pump was out of service.
One hundred twenty nine hours 25 minutes between July 22nd and July 27th when the 1A charging pump was out of service, Eighty hours thirteen minutes between July 13th and July 17th when the 2A charging pump was out of service.
Ten hours more than were recorded when the 2A charging pump was out of service between August 5th and August 8th.
Twelve hours fifty five minutes between August 6th and August 7th when the 2A hydrazine pump, a portion of a Containment Spray train, was out of service, and Seventeen hours twelve minutes on August 18th when the 2A hydrazine pump, a portion of a Containment Spray train, was out of service.
- 4. The system owner did not document the July 25, 1996, potential maintenance preventable functional failure of the 1A Boric Acid Makeup pump on a Condition Report.
This is a Severity Level IV Violation (Supplement I) l I
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Docket Nos.: 50-335 and 50-389 License Nos.. DPR-67 and NPF-16 Report No.: 50-335/96-13 and 50-389/96-13 Licensee: Flordia Power & Light Company Facility: St. Lucie Nuclear Plant Units 1 & 2 Location: Hutchinson Island St. Lucie County. Florida ;
Dates: September 16 - 20, 1996 I
Team Leader: W. Holland, Reactor Inspector, Maintenance Branch j Inspectors: W. Bearden Reactor Inspector, Maintenance Branch J. Coley, Reactor Inspector Special Inspection Branch R. Gibbs, Reactor Inspector, Maintenance Branch W. Rogers, Senior Reactor Analyst J. Shackelford, Reli'bility and Risk Analyst, NRR Approved By: H. Christensen, Chief. Maintenance Branch Division of Reactor Safety l
EXEC lT[IVE
SUMMARY
-St. Lucie Nuclebe Plant. Units 1 and 2 NRC Inspection Report 60-335/96-13 and 50-389/96-13 This inspection included a review of the licensee *s implementation of 10 CFR )
50.65 " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" [the Maintenance Rule]. The report covers a 1-week period of inspection by inspectors from Region II and the Office of Nuclear Reactor Regulation.
Ooerations Licensed operators, with some exceptions, understood their s and responsibilities for implementing the Maintenance Rule. Two pecific duties operators understanding of duties and responsibilities for implementation of the Rule was weak. Shift technical advisors were cognizant and knowledgeable of their roles associated with the Maintenance Rule.(Section 04.1).
Maintenance Required structures, systems, and components, with the exception of three systems and radiation monitoring components were included within the scope of the Rule. A violation was identified for failure to include all structures, systems, and components within .the scope of the Rule as required by 10 CFR 50.65 (b) (Section M1.1).
Plans for performing.the periodic evaluation met the requirements of the Rule. In addition, the quarterly report for structures, systems, and components performance was considered a positive indicator of the licensee implementation of an assessment process at a frequency exceeding ,
requirements (Section M1.3).
The approach to balancing reliability and unavailability was reasonable.
However, the measure of reliability for risk significant systems did not meet the requirement of the Maintenance Rule. Thus, while the overall l ap3 roach was acceptable, the implementation of this approach would not be aclievable until such time as acceptable performance criteria for reliability of risk significant systems was developed (Section M1.4).
The licensee has considered safety in establishment of goals and monitoring for Systems and Components reviewed. Industry wide operating experience was used'and corrective actions were appropriate. A violation !
was- identified for failure to . follow procedures associated with Rule implementation. Also, some weaknesses were identified. Examples were:
failure to use vendor established acceptance criteria for verifying acceptable contact point resistance in the governor coil for the turbine pump on the Unit 1 'C' Auxiliary Feedwater train, untimely documentation of the cause determination for unit unplanned unavailabi nty, and ,
implementation of licensee procedural requirements associated with the
.4.16 Kilovolt breakers (Section IM.6). !
The licensee had adequately addressed 10 CFR 50.63 Station Blackout Rule requirements and these requirements had been implemented into the ;
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Emergency Diesel Generator performance criteria (Section IM.6).
For most of the structures, systems, and components reviewed, performance criteria was established, industry-wide operating experience was considered, appropriate trending was being performed. and corrective action was taken when structures, systems. or components failed to meet performance criteria, or when a structure, system. or component ;
experienced a maintenance preventable functional failure. Structures were '
being monitored and a systematic program for monitoring had been established. An item was identified for followup on licensee actions to provide performance criteria for structures after industry resolution of this Issue. Several additional examples of the violation for Failure to follow procedures associated with Rule implementation were identified. In j addition, weaknesses were identified. Examples were: performance criteria j did not clearly address all maintenance rule functions of the Reactor Protection System, several radiation monitors had not been included in the scope of the Rule, lack of clear definition of system boundaries l associated with steam generator tubes and numerous deficiencies in the l way licensee personnel accomplished monitoring of systems and components I to established performance criteria (Section M1.7).
Issuance of the Maintenance Rule Administrator periodic memorandum, which provided an additional barrier to identify maintenance preventable functional failures was considered a strength (Section M1.7).
Plant material condition observed during walkdowns was generally good. l Preservation of equipment by painting was considered to be very good, '
considering the environment the plant is located in. One example of poor housekeeping (unattended step ladders) was observed in Unit 1 safety-related pump rooms (Section M2.1).
The licensee's December 1995 assessment, and July 1996 audit provided .
significant insight, allowing corrective actions to be taken to institute j an adequate 3rogram for compliance with 10 CFR 50.65. The assessment and audit proviced meaningful feedback to management, and was considered a strength. However, this inspection determined the program was not functioning well, due in part to the short time it has been in place !
coupled with many new and inexperienced system engineers (system owners) who are not totally familiar with their systems or program requirements !
(Section M7.1).
Enaineerina The licensee's overall cuantitative approach to perform risk ranking for structures, systems, anc components in the scope of the Maintenance Rule
- using the probabilistic safety analysis approach was adequate. A violation was identified for failure to establish performance criteria commensurate with safety. Other weaknesses rioted included
- ranking of initiating events and recovery aptions not performed in a quanti 1 dive 4 manner, re-ranking of structures, systems, and components following sensitivity study for unavailability not performed, approach for Bayesian updating for certain systems, structures, and components needed i improvement, and expert panel guidance on assessing risk significance of shutdown conditions was weak (Section M1.2).
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( -The overall approach to assessing the impact before taking systems or components out of service was adequate. Weaknesses noted were: the exclusion of Mode 4 operations, lack of assessments for non-risk significant structures, systems, and component combinations, omissions from the pre-evaluated maintenance risk assessment matrix, and inconsistent interpretation of the definition of maintenance activities. -
The licensee's systematic approach to the development of the pre-evaluated maintenance risk assessment matrix was considered a strength (Section M1.5).
The licensee's predictive maintenance program was being implemented in a l manner which provided the licensee with analysis results to focus on ,
problems prior to equipment failure. This area was considered a strength
! (Section E2.1).
Most of the system engineers interviewed were newly assigned and lacked some system knowledge and historical information for their assigned systems. Although they understood specific requirements of the Maintenance Rule they did not always understand how to apply the rule to :
their systems. The fact that the licensee assigned systems engineers so ;
late in the process for implementation of the rule is viewed as the major contributing factor to the deficiencies noted during this inspection.
! Four system engineers were knowledgeable of their systems and implementing the Rule requirements in a good manner (E4.1).
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. VIOLATION A M1.1 Scooe of Structures. Systems. and Comoonents Included Within the Rule
- a. Insoection Scone (62706)
' Prior to the onsite inspection, the inspectors reviewed the ST. Lucie Final Safety Analysis Report. Licensee Event Reports, the ' Emergency Operating Procedures, previous NRC Inspection Reports, and other information provided by the licensee. The team selected an independent sample of structures, systems, and components ' that the team believed should'be included within the scope of the rule, which was not classified as such by the licensee. During the onsite' portion of the inspection, the inspectors used this list to determine if the licensee had adequately identified the structures. systems, and componer,Ls that should be included in the scope of the rule in accordance with 10 CFR 50.65 (b).
- b. Observations and Findinas
! The licensee appointed an expert panel to perform several maintenance rule implementation functions including establishing the scope of the Maintenance Rule. The panel reviewed 106 systems in the plant and determined that 72 were in the scope of the rule. In addition. 54 structures were placed within the scope of the rule.
l The inspectors reviewed the licensee's data base and verified that all required structures, systems, and components were included in the rule !
with the exception of the following: ]
The licensee had not included the Polst Accident Sampling System in-the scope of the Maintenance Rule. Further review of this system .
determined that the system would be used during the periormance of i the sites Emergency Operating Procedures to aid in determination of l offsite evacuation. Specific examples of this were found in the ,
Emergency Operating Procedures for a Loss of Coolant Accident (EOP- 1 03, Revision 14) and Steam Generator Tube Ru)ture'(E0P-04 Revision 12). This is contrary to 10 CFR 50.65. whica requires inclusion of SSCs that mitigate the consequences of an accident and are included !
in plant E0Ps. The licensee issued Condition Report 96-2278 during the inspection to re-evaluate this system for inclusion in the l Maintenance Rule. ,
The licensee had not included the site Coninunications System in the scope of the Maintenance Rule. Further review of this system determined that the system is used to mitigate the consequences of accidents or transients, and is vital in the proper performance of all Off-Normal and Emergency Operating Procedures. A specific reference to the use of the plants Communications System was found l l
in the Station Blackout Crosstie Emergency Operating Procedure (EOP-
! 99, Revision 17). This is contrary to 10 CFR 50.65, which requires
- . inclusion of SSCs that mitigate the consequences of an accident and are included in plant E0Ps. The licensee issued Condition Report l 96-2278 during the inspection to re-evaluate this system for inclusion in the Maintenance Rule.
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i The licensee had not included the Service Air System in the scope of i the Maintenance Rule. Review of operator logs determined that the i Service Air System Air compressors on Unit 1 had been crosstied to the Instrument Air System on July 13, 1996 in support of plant l The Instrument Air System is included under shutdown conditions.
the scope of the rule. Discussion of this issue with licensee- 3 l- personnel determined that it was licensee policy to routinely '
crosstie the Service Air System Compressors to the Instrument Air System during outage conditions. Further investigation determined !
that this configuration could affect the operation of the safety-related Low Pressure Safety Injection System operating ' in the shutdown cooling mode. 10 CFR 50.65 requires inclusion of non-
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t safety related systems whose failure could prevent safety related i L SSCs from fulfilling their safety function and therefore, the l l inspectors considered the Service Air System compressors should be i
! included in the scope of the rule. The licensee issued Condition :
l: Report 96-2278 during the inspection to re-evaluate this system for l inclusion in the Maintenance Rule.
t l The inspection team was aware of a history of problems with l radiation monitors, and, as a result, a review of the Radiation L Monitoring System for scoping within the Maintenance Rule was l conducted, even though the Radiation Monitoring System was included l in the rule by the licensee. This review resulted in the l determination that the Main Steam Radiation Monitors had not been included in the scope of the Maintenance Rule. even though both the Main Steam System and the Radiation Monitoring System had been .,
included in the rule. This deficiency was the result of the lack of '
specific definition of the boundaries between the two systems, Upon discovery of the deficiency the licensee issued Condition Report 96-l 2264. Preliminary investigation by the licensee also identified the '
l fact that the Unit 1 Containment Air Radiation Monitors were also not included in the scope of the rule. The Main Steam Radiation Monitors are used to mitigate the consequences of an accident and -
are included in plant E0Ps. A specific example of their use is in the Steam Generator Tube Rupture E0P (EOP-04, Revision 12). This is contrary to 10 CFR 50.65, which requires inclusion of SSCs that
[ mitigate the consequences of an accident and are included in plant E0Ps.
10 CFR 50.65 (b) establishes the scoping criteria for selection of safety r'
related 'and non-safety related structures, systems, or components to' be included within the Maintenance Rule program. Scoping criteria includes
, safety-related structures, systems, or components that are relied upon to
! remain functional during and following design basis events to ensure the l integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the 10 CFR part 100 i guidelines: and non-safety related structures, systems, or components that l are relied upon to mitigate accidents or transients or are used in the i plant emergency operating procedures, or whose failure could prevent safety-related structures, systems, and components from fulfilling their i safety-related function, or whose failure could cause a reactor scram or i
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l actuation of a safety-related system. The deficiencies concerning sco)ing discussed above are included as examples of a Violation of t1ese !
requirements, and are cited as Violation 50-335, 389/96-13-01. Failure to
! Include All Structures, Systems, and Components in the Scope of the ,
i Maintenance Rule as Required by 10 CFR 50.65 (b). j i
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VIOLATION B M1.2 Safety or Risk Determination
- a. Insnection Scooe (62706)
Paragraph (a)(1) of the rule requires that goals be commensurate with safety. Implementation of the rule using the guidance contained in NUMARC 93-01 requires that safety be taken into account when setting ]erformance ;
criteria and monitoring under (a)(2) of the rule. T1is safety '
consideration would then be used to determine if the SSCs should be monitored at the train or plant level. The inspectors reviewed the '
methods that the licensee had established for making these required safety determinations. The inspectors also reviewed the safety determinations that were make for the systems that were reviewed in detail during this inspection. j
- b. Observations and Findinos b.2 Performance Criteria The inspectors reviewed the licensee's performance criteria to determine i if the licensee had adequately set performance criteria under (a)(2) of !
the maintenance rule consistent with the assumptions used to establish the i safety significance. Section 9.3.2 of NUMARC 93-01 recommends that risk '
significant SSC performance criteria be set to assure that the -
availability and reliability assumptions used in the risk' determining I analysis (i .e. PRA) are maintained. PSL elected to use performance ;
criteria for unavailability and reliability different than what was used )
in the risk determination for many of the risk significant SSCs. The PSA used actual plant specific values for unavailability and reliability. PSL selected a performance criterion of two maintenance preventable functional failures (MPFFs) per operating cycle for reliability for almost all risk significant SSCs and used somewhat higher unavailability criteria for a >
' number of SSCs.
P PSL performed a sensitivity analysis that demonstrated that the ase of the unavailability performance criteria would not have had a significant impact on total CDF. (i.e. the use of the maintenance rule criteria would have resulted in an approximately 20 % increase in'CDF if all of the SSCs were assumed to be simultaneously at the upper end of their allowable values). The inspectors noted that the licensee did not perform an additional risk ranking to determine that the overall ranking was not adversely affected by the new data. However based on the final results, ;
the inspectors did not determine that this would have resulted in any new :
SSCs being categorized as risk significant since (with the exception of Turbine Building HVAC) all of the PSA modelled systems had already been categorized as risk significant.
However, at the time of the inspection. PSL had not performed a similar analysis that demonstrated that the performance criteria used for reliability preserved the assumptions used in the PRA or that the use of the criterion did not have an adverse impact on risk ranking. The inspectors noted that there was no relationship established between the
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- criterion and the failure probability assumptions in the' PRA since:the i
. number of function demands and/or equipment run time were not tracked. '
.Thus, widely'different' actual SSC reliability estimates (probability of :
failure u)on demand) could result from the same number of MPFFs in a given time per od if the number of demands were different. This item is '
considered to be a violation of 10 CFR 50.65 (a)(1). " Failure to Establish .
Performance Criteria Commensurate with Safety". (VIO 50-335, 389/96 02).
'Also, the licensee did not establish appropriate performance criteria for the' Unit 2 - to Unit 1 condensate cross-tie valves. These valves were categorized as risk significant by calculation PSL-1FJR-94-002. " Risk <
. Significance Determinations - of PSL Unit 1 Systems." These valves were considered part of the auxiliary feedwater system in the systems summary '
report, even though they contained a condensate system equipment number.
The performance criteria for the auxiliary feedwater system' did not '
include performance criteria, other -than 2 MPFFs/18 month period, that would be germane to these cross-tie valves. However, the cross-tie valves were rarely operated and probably would not be used twice during any 18 In addition, as previously discussed. MPFFs without month period. .!
correlation to the underlying assumptions used for risk ranking . is i inadequate. Consequently, this is another example of violation 50-335. !
389/96-13-02. Failure to Establish Performance Criteria Commensurate with :
Safety. ,
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VIOLATION C M1,6 Goal Settina and Monitorina for (a)(1) SSCs
- a. Insoection Scooe (62706)
Paragraph (a)(ly of the Rule requires, in part, that licensees shall monitor the performance or condition of structures, systems, or components against licensee-established goals in a manner sufficient to provide reasonable assurance the SSCs are capable of fulfilling-their intended functions. The Rule further requires goals to be established commensurate with safety and industry-wide operating experience be taken into account, where practical. Also, when the performance or condition of the SSC does not meet established goals, appropriate corrective action shall be taken.
The inspectors reviewed the systems and components listed below which the licensee had established goals for monitoring of performance to provide reasonable assurance the system or components were capable of fulfilling their intended function. The inspectors verified that industry-wide operating experience was considerec, where practical, that appropriate monitoring was being performed, and that corrective action was taken when structures, systems, or components failed to meet goal (s), or when a structure, system, or. component experienced a maintenance preventable functional failure.
The inspectors reviewed program documents and records for the six systems or components the licensee had placed in the (a)(1) category in order to evaluate this area. The inspectors also discussed the program with the Maintenance Rule Administrator, system engineers, and other licensee
. personnel.
- b. Observations and Findinas b.3 4.16 KV Switchaear and Breakers The licensee had experienced several repeat Maintenance Preventable Functional. Failures (MPFFs) involving failure of 4.16 KV Breakers due to floor trip)er and latch switch misadjustments. As a result of these failures t1e licensee had put these breakers in the Maintenance Rule (a)(1) category. The inspector reviewed the corrective action for these failures, and the goals and monitoring under the (a)(1) status, and concluded that the corrective action, goals, and monitoring were appropriate. The inspector also reviewed additional work order data concerning performance of these breakers for the period January 1995 to j the.beginning of the inspection. This review determined that there were <
two additional repeat MPFFs, and a significant number of breaker unavailability hours, which had not been identified in the licensee's Maintenance Rule Quarterly Report as follows:
- Work Orders 95007753-01 and 95007984-01 performed preventive I maintenance on the 4.16 KV Station Blackout Crosstie Breakers, and no unavailability of : these breakers was trended again: L the unavailab.ility performance criteria for these breakers in the
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licensee's Maintenance Rule Quarterly report dated July 9.1996. l W0s 95021809-01 and 95023498-01 reported repetitive maintenance preventable functional failures for the 4.16 KV breakers for the pressurizer heater electrical supply which were not shown in the licensee's Maintenance Rule Quarterly report dated July 9.1996.
This was contrary to licensee procedure ADM 17.08. Revision 7. paragraph i 7.6.4 and 7.11.2. A. which require performance monitoring be accomplished l by tracking specific (SSC Level) and/or Plant Level Performance Criteria !
- and repetitive maintenance preventable functional failures , and the 1 4
documentation of this information the licensee's Maintenance Rule Quarterly Reports. Failure to track repeat MPFFs and SB0 breaker unavailability hours against their performance criteria were identified as examples of Violation 50-335, 389/96-13-03. Failure to Follow Procedures for Implementation of the Maintenance Rule.
M1.7 Preventative Maintenance and Trendina for (a)(2) SSCs I' a. Insoection Scone (62706)
Paragraph (a)(2) of the Rule states that monitoring as required in paragraph (a)(1) is not required where it has been demonstrated that the performance or condition of a SSC is being effectively controlled through
- the performance of appropriate preventative maintenance such that the SSC remains capable of performing its intended function.
The inspectors reviewed selected SCCs listed below for which the licensee I had established performance criteria, and was trending performance to !
verify that appropriate preventative maintenance was being performed, such that the SSCs remain capable of performing th ir intended function. The inspectors verified that industry-wMe operating experience was considered, where practical, that approariate trending was being performed, that safety was considered when performance criteria was established, and that corrective action was taken when structures.
systems or components failed to meet performance criteria or when a 2
structure system, or component experienced a maintenance preventable functional failure.
The inspectors reviewed program documents and records for selected structures, systems, or components the licensee had placed in the (a)(2) category in order to evaluate this area. The inspectors also discussed
. the program with the Maintenance Rule Administrator, system engineers, maintenance supervisors and other licensee personnel. In addition, the inspectors reviewed specific program areas based on review of operator j logs and equipment out of. service logs.
- b. Observations and Findinas b.3 Turbine Coolina Water System The licensee had experienced two failures in the Turbine Cooling Water (TCW) System on Unit 2. which caused manual reactor trips during the first six months of 1996. This was below the performance criteria (less than or
equal to two failures causing manual reactor trips within the past twelve months) established by the licensee in order to keep the system in Maintenance Rule category (a)(2). However, the team determined that this criteria had no technical basis as discussed in paragraph M1.2. Even though the TCW System had been classified as (a)(2). the system had been ;
reported to management as a system requiring " heightened awareness" in the '
Maintenance Rule Quarterly Report dated July 9. 1996. Review of the TCW .
failures determined that they were caused by the failure of the same temperature control valve (TCV-13-15), but the failures were due to two different causes (one failure involving electrical logic and one failure involving disconnect of the operator actuator feedback arm from the .
valve). The inspector reviewed the work order history for valve TCV-13-15 !
during the previous twelve months, and no additional failures of the valve l were found. In addition, the inspector reviewed the corrective action for i these two failures. The inspector determined that corrective action was l appropriate with the one exception: The corrective action for the actuator arm failure had considered similar valves in the TCW system for both units: however, it had not considered similar valves in other plant systems. This is contrary to licensee procedure ADM 17.08. Revision 7.
- paragraph 7.8.4 which requires that cause determinations for failures l shall consider any generic implications for structures, systems and components other than the one being evaluated. The licensee issued Plant Managers Action Item (PMAI) 96-09-210 when advised of this deficiency.
Failure to consider the ';;.;eric implications of a Maintenance Preventable ,
Functional Failure % included as an example of a Violation 50-335. l 389/96-13-03. Failure to Follow Procedures for Implementation of the !
Maintenance Rule. l b.6 Unavailability I
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t The licensee's general implementation direction to meet this requirement was contained in Administrative Procedure ADM 17.08. " Implementation of 10 CFR 50.65. The Maintenance Rule." Performance criteria was established for all SSCs to set a standard for adequate performance with the performance criteria for each system documented as part of Appendix B to ADM 17.08. Section 7.6.4 of the ADM required, in part, that " Performance monitoring shall be accomplished by tracking Specific (SSC l.e wl) and/or Plant Level Performance Criteria and repetitive maintenance preventable functional failures..." Section 4.4.3 of the ADM stated that the " System owners are responsible for monitoring systems, structures and components for compliance to performance criteria." Further guidance on performance monitoring was provided in Systems and Components Engineering Guideline No. SCEG-006. Guideline for Monitoring Maintenance Effectiveness by Maintenance Rule System Owners." Section 7.3.1.A directed system owners
'to use the Equipment out uf Service Log to determine the out of service l hours.
Appendix. B of ADM 17 08 identified the Chemical and Volume Control and Containment Spray Systems as risk significant with specific availability performance for Containment Spray trains A/B and Chemical and Volume Control charging pumps A/B/C. The specific unavailability hours were contained in the quarterly system summaries report.
The inspector reviewed . selected Equipment Out of Service Logs and
determined unavailability hours tracked by the system owner associated with the Unit I and Unit 2 Chemical and Volume Control Systems were not accurate. Specifically, the unavailability hours did not include:
Five hours six minutes on July 10 when the 2A charging pump was out of service One hundred twenty nine hours 25 minutes between July 22nd and July 27th when the 1A charging pump was out of service Eighty hours thirteen minutes between July 13th and July 17th when the 2A charging pump was out of service Ten hours more than were recorded when the 2A charging pump was out of service between August 5th and August 8th.
As determined through interview, the system owrier was using the working equipment clearance order log to ascertain when the charging pumps were out of service. If identified in the log the specific equipment out of service log entry would be reviewea to determine the actual time the pump was unavailable. However, this clearance log did not include all of the equipment out of service entries.
The unavailability hours tracked by the system owner associated with the Unit 2 Containment Spray System for August 1996 were not accurate.
Specifically, unavailability hours for the hydrazine pump were not included as part of the hours. The hydrazine pump was considered part of a containment s] ray train per interview with the Maintenance Rule Administrator anc identified as a key component in the system summary for the containment spray (system 7). Based upon interview, the system owner did not know the hydrazine pump was included in the train. Therefore the tracked unavailability hours did not include 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 55 minutes between August 6th and August 7th, or 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> 12 minutes on August 18th when the 2A hydrazine pump was out of service.
Failure to track equipment out of service for comparison to performance criteria as required by procedure is identified as an example of Violation 50-335, 389/96-13-03. Failure to Follow Procedures for Implementation of the Maintenance Rule.
b.7 Maintenance Preventable Functional Failures j ADM 17.08 designated other performance criteria besides unavailability for i monitoring risk significant equipment, such as MPFFs. Monitoring of MPFFs I was discussed in section 4.4.4 of ADM 17.08 which stated " System owners are responsible for identifying potential maintenance preventable Functional Failures and bringing them to the attention of Management and !
the MRA via the Condition Report Process." Section 7.8 further required i that a functional failure of a risk significant structure, system, or ;
component, even if the goal or performance criteria was met, would receive a cause determination which would be documented as a Condition Report.
The inspector requested the Condition Reports for several potential MPFFs identified through review of the Equipment Out of Service and unit I
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specific chronological logs. Reports were provided for all but the !
. unexpected tripping of the 1A Boric Acid Makeup pump on July 25, 1996. i
! Consequently. Condition Report 96-2293 was initiated on September 19th.
l Failure of the system owner to initiate a Condition Re) ort prior to inspector involvement is identified as an example of Vio~ ation 50-335, 4
389/96-13-03. Failure to Follow Procedures for Implementation of the 4
Maintenance Rule.
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