IR 05000313/1987030
| ML20237E464 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/23/1987 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8712290009 | |
| Download: ML20237E464 (1) | |
Text
November 30, 1987
SUBJECT:
Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License No. DPR-51 and NPF-6 Response to Inspection Report 50-313/87-30 and 50-368/87-30
Dear Mr. Callan:
Pursuant to the provisions of 10CFR2.201, a response to the violation identified in the subject inspection report is submitted.
Sincerely
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M. tevine xecutive Director, AND Site Operations JML: PLM: dm enclosure cc w/ encl:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
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Notice of Violation Unit 1 Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.
Paragraph I.2 of Appendix "A" to Regulatory Guide 1.33, November 1972, states that preventive maintenance schedules should be developed to specify lubrication schedules.
Unit 2 Technical Specification 6.8.1 includes an identical requirement as noted above except that it references Regulatory Guide 1.33, February 1978.
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Paragraph 9.b of Appendix "A" to Regulatory Guide 1.33, February 1978, states that preventive maintenance schedules should be developed to specify lubrication schedules.
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Paragraph 5.1.1 of the licensee's Operations Quality Assurance Manual requires that control of activities which affect safety, such as maintenance, be covered by written procedures which comply with the format, content, and philosophy of the guidelines of Regulatory Guide 1.33, February 1978, and ANSI N18.7-1976.
Paragraph 5.2.7.1 of ANSI N18.7-1976 states, in part, that a preventive maintenance program for safety-related components shall be established and maintained which prescribes the frequency and type of maintenance to be performed.
Contrary to the above, during this inspection period, the NRC l
inspectors determined that the licensee failed to have adequate l
lubrication schedules for safety-related pump couplings as evidenced by the following examples:
1.
The High Pressure Injection (HPI) Pump P36C motor to gear box coupling had no record of lubrication since 1982.
On August 29, 1987, this coupling failed while the pump was in routine makeup operation, rendering the pump inoperable.
2.
The licensee was unable to find lubrication records for the following pump couplings subsequent to the date indicated below:
HPI Pump P36A - motor coupling No record HPI Pump P36C pump coupling July 1979 Low Pressure Injection (LPI) Pump P34A May 1982 LPI Pump P34B No record Reactor Building Spray (RBS) Pump P35A April 1979 RBS Pump P35B No record'
Emergency Feedwater Pump 2P7B No record This is a Severity Level IV violation.
(313;368/8730-01)(Supplement I)
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Response to Violation 313-368/8730-01 (1) The reason for the violation if admitted:
AP&L admits that the lubrication schedules for safety-related pump couplings were inadequate as evidenced by the failure of P-36C on August 29, 1987. The root cause of the inadequate schedules relates directly to inadequate implementation of the existing Preventive Maintenance (PM) Program.
The PM tesk requiring the lubrication of the couplings on P-36C was overdue as a result of weaknesses in the PM program.
(2) The corrective steps that have been taken and the results achieved:
The failed coupling on pump P-36C was replaced and properly lubricated.
The couplings on the other two high pressure injection pumps were inspected and lubricated.
No inadequate
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coupling lubrication or deterioration resulting from excessive wear was evident.
A review of other safety-related pumps was initiated to determine when each was last uncoupled and lubricated.
The results indicated that thirteen additional safety-related
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pumps had not been lubricated within an acceptable time period l
based on schedules recommended in the vendor technical manuals, lubrication manual, maintenance procedures, or PM schedules.
Job Requests were issued for these thirteen pumps and six
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non-safety-related pumps. The safety-related jobs were performed on an accelerated schedule and were completed for both units by September 15, 1987.
Based on visual inspections, no unusual wear was identified and no couplings were found with inadequate lubricant.
This indicated that the P-36C failure could have been an isolated case and was not indicative that overdue PM tasks generically affect equipment operability.
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To address generic implications, an action plan was developed to determine the extent of overdue preventive maintenance tasks for safety-related equipment.
A total of more than two-hundred
safety-related components for ANO-1 and ANO-2 were identified as
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having overdue PMs. The list of components was reviewed against corrective maintenance activities which would have satisfied the PM requirements.
The list of components was further reviewed by Operations Technical Support for identification of components whose failure could impact system operability.
Additional reviews by Plant Engineering evaluated surveillance activities
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for indication of trending programs that would identify degradation.
These actions resulted in a final list of 13 components for AND-1 and 35 components for ANO-2 for which job requests were issued for performance of the preventive maintenance tasks.
The job orders for ANO-1 components were completed during the
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mid-cycle outage during October, 1987.
The job orders for ANO-2 components are currently being reviewed and will be completed during the refueling outage beginning in February,1988.
As no operability concerns were identiffed that required immediate action, the above schedule was felt to be adequate.
(3) The corrective steps that will be taken to avoid further
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violations:
A Preventive Maintenance Improvement Program (PMIP) has been under development. This effort was initiated due to recognition of weaknesses in the current PM program regarding scheduling of activities, adequacy of procedures, and management of the overdue tasks.
The PMIP utilizes the i
updated vendor technical manuals developed for the Station l
Information Management System component database.
The vendor PM recommendations, as well as plant experience and engineering
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evaluations, provide a comprehensive technical basis for
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establishing required tasks and performance schedules for equipment preventive maintenance.
Procedures and repetitive job orders are being developed as part of the process.
The program should be completely implemented by October,1988.
Until the PMIP is complete, a change to the current PM program will require Maintenance Superintendents to review overdue PM tasks.
They will either request the Work Control Center to schedule the task or request an operability assessment of the effect of not performing the task.
(4) The date when full compliance will be achieved:
Job orders for preventive maintenance on overdue components of concern for ANO-1 were completed during the mid-cycle outage which started October 16, 1987.
For ANO-2. overdue PMs for components of concern will be completed prior to start up from the February 15, 1988 refueling outage.
The PMIP implementation effort is expected to be completed by October, 1988.
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