IR 05000324/1990042

Insp Repts 50-324/90-42 & 50-325/90-42 on 900924-28.No Violations or Deviations Noted.Major Areas Inspected: Licensee Independent Action Plan Action Items to Correct Three Weaknesses Identified in 1989 by NRC

ML20058F313
Person / Time
Site:	Brunswick
Issue date:	10/23/1990
From:	Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058F308	List: IR 05000324/1990042 ML20058F306
References
50-324-90-42, 50-325-90-42, NUDOCS 9011080204
Download: ML20058F313 (7)

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~ UNITED STATES W.

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. Report Nos.:.50-325/90-42 and 50-324/90-42

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FDocket"Nos.': 50-325 and 50-324-License Nos.:

DPR-71 and DPR-62-r'

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Facility Namei'l Brunswick 1 and;2-

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Inspection Conducted:'. September 24-28 1990.

Inspector:: -

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Approve'd'by:

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.B'ake, Chief.

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EM rials and Processes Section lE gineering Branch

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Division'of Reacto_r Safety

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SUMMARY l

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P.','... Scope:

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LThisiroutine,Lannounced inspection wasL conducted in the area of followup.on

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licensee-IndependentActionPlan-(IAP)Lactionitems-tocorrect~three, weaknesses

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op>w tidentified in 1989.by an.NR_C Diagnostic Evaluation. Team.;

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L'icens'eeilAP --actionsJ o correct 'each weak' ness were determined to have' been-(

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' compt' ted, lHowever, document' files and"other information provided regarding '

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.K Tactions-.to correctitwo of the' weaknesses were. insufficient to' demonstrate that

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Y" the Ja' tions, were effectiveL in Lcorrecting the -associated. weaknesses.. - ForJ the1 c

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+ ithirdc item,1which appeared' of 11 esser importance, data'.was sufficient to FT

' determine that the weakness 1had been adequately corrected.-

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JInlth'e. areas.; inspected,. violations or deviations' we're not identified.

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9011080204 901029

PDR ADOCK 05000324

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

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R. 'Aldridge, Site Work Force Control Group Chairman c

'*K. Altman, Manager, Regulatory Compliance S. Bertz, Supervisor, Mechanical Planning

• K. Core,. Senior Specialist, Control and Administration

• W. Dorman, Manager, Quality Assurance / Quality Control

.P.- Godson, Inservice Inspection Specialist

• J.-Harness, Generel Manager

- K. Harris, Senior Specialist-Investigations, Regulatory Compliance

• R..Helme, Manager, Technical Services

• J.' Holder, Manager,0utage Management and Modifications (OMM)

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.T. Jones, Speciali't, Regulatory Compliance

• J.'Moyer, Administrative Assistant to the Plant General Manager

• P. Musser, Manager 'iaintenance Staff, Maintenance.

'*G. Peeler Manager oJ Planning and Scheduling OMM W. Simpson, Manager, Control'and Administration

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• R. Warden, Manager, Maintenance

• L. Wheatley, Supervisor, Inservice Inspection / Inservice Testing

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NRC Resident' Inspector

• R. Prevatte', Senior Resident Inspector

-* Attended exit interview

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Acronyms and' initialisms used throughout this report are listed in the-1ast paragraph.

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Followup on Independent Action Plan (IAP) Action Items Lto Correct Weaknesses Identified by the 1989 NRC Diagnostic Evaluation (92701)

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General The inspector examined the status of licensee actions to correct three Brunswick performance weaknesses is

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1989 Diagnostic Evaluation.

These weaknesses bad previously-been

' designated as-- inspector followup items in NRC Inspection-t 50-325,324/89-34.

The licensee developed and incorporated action items for correction

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of weaknesses identified by )the Diagnostic Evaluation into their-Integrated Action - Plan (IAP.

This plan addresses ' both NRC Diagnostic Evaluation findings and improvements undertaken by the

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licensee on their own initiative.

Two levels of action items are specified in the plan - summary (Level 1) and subordinate (Level 2).

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Individual responsibilities are assigned for every Level 1 and 2 item.

The licensee's current internal requirements for monitoring and

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documenting the effectiveness of the IAP implementation efforts are described in a memo from the Manager, Control and Administration to the Vice President, Brunswick Nuclear Project, dated August 6, 1990.

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They are as follows:

(1) -Monthly Status Reports: Each month the Manager, Control and Administration compiles a report of IAP action item status based on information obtained from tevel 1 managers assigned responsibilities for the items, This report contains information on implementation schedule performance -

such as the original and current target dates for completion.

It is provided to CP&L Senior Management and to the NRC.

(2) _ Independent Assessment of Completion: After completion of a Level 1 action item an assessment is made by an

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-i ndependent organization to evaluate the extent of completion of the Level 1 item and its associated Level 2

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action items, to evaluate the documentary evidence of completion and to look at measures in place to ensure improvement can be sustained.

.(3)' Reporting on Effectiveness _ of Completed ' Actions (by Managers Responsible for the Items): Level 1 managers are responsible to report on the effectiveness of their completed Level 1 actions, providing documentary ' evidence

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that the' IAP action has. produced -the intended improvement and' that the improvement has been institutionalized.

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reporting is to be monthly for IAP items considered open

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by the NRC and quarterly for items not considered open by

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the NRC.

(4) Auditing of Continued Effectiveness (by Corporate QA):

Audits of the effectiveness of the IAP_are to be performed

by Corporate QA.

The timing, frequency and depth of the audits are determined by CQA on the basis of perceived significance, resource availability, relationship to other

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planned audits, etc.

(5) Documentation of' Completed Activities:

Documentary evidence of completed IAP activities is collected and maintained by the Control and Administration organization.

For completed Level 1 action items this includes: evidence required to be provided by the action item managers to

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demonstrate item completion, reports of independent

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verifications of completeness (see (2) above) and effectiveness (see (4) above), and the Level 1 managers monthly or quarterly reports on the effectiveness of their completed items (see (3) above).

Subsections 2.b, 2.c, and 2.d below describe the IFIs examined by the NRC inspector and his findings, b.

(0 pen) IFI 50-325, 324/89-34-19, Followup on Implementation and Effectiveness of Maintenance Backlog Improvements in IAP Item D2 (Ref. 2.1.3.6)

This IFI represents a concern that the licensee's nonoutage maintenance work backlog was too high.

The concern was identified by the NRC Diagnostic Evaluation Team (DET) in April-1989, at which time the backlog was about 3200 work requests.

The DET estimated

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that this represented about 7 weeks work in the absence of any.

edditions.

From a review of related IAP action item files, review of posted and separately provided maintenance performance indicator data, and discussions with the Maintenance Staff Manager whom the licensee -

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designated'as the contact for this item, the inspector found that the Level 1 and 2 action items had been completed.

Based on number of open nonoutage work requests, it appeared that the backlog had been greatly improved since the DET. review - a reduction to 1500 from the 3200 noted by the DET. -However, in terms of weeks of work, the backlog' remains about the. 7 weeks stated by the DET.. The DET reported that work requests were being completed at a rate of about 1430 per week at that time; currently the rate appears to be about 200 per week..

In discussions, the inspector was informed that the-reduction in numbers of work requests represented an actual reduction in the corrective maintenance backlog and that the rate at

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which the. requests were being -completed was lower now largely because greater emphasis and time was being directed to preventive maintenance activities that_were not covered by work requests.

<1 There was insufficient data in' the Control and Administration IAP item file to demonstrate that corrective maintenance work had been replaced by preventive maintenance or to otherwise explain the high backlog in-terms of weeks of work.

In response to the inspectors questions on.this matter, the Maintenance Staff Manager. indicated he would ~ provide further. data to show that the backlog should not be considered excessive.

However, before he could do so, a scram.

occurred and he was required to divert his attention to participation in its investigation and no further data was provided.

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The licensee's response to the DET, transmitted to the NRC in their letter dated September 27. 1989, indicated (in Section II, page 27)

that backlog goals would be established for each work group within the maintenance unit.

Additionally, the procedure developed by the

' licensee to manage the maintenance backlog (S0P 2.45, Revision 0),

indicates establishment of backlog goals.

. These latter goals include corrective maintenance greater than 3 months old, out-of-service control room instruments, preventive maintenance items overdue, and. preventive maintenance to corrective maintenance backlog.

The inspector considers that data on the licensee's l

performance with regard to the above goals would indicate ~ the effectiveness of the licensee's actions to address this IFI.

The IFI 'will remain open pending review of work group and S0P 2.45 backlog data in a subsequent NRC Region II-inspection, c.

(0 pen) IFI. 50-325, 324/89-34-21:

Followup on Implementation. and j

Effectiveness of Developed. Post Maintenance Testing Guidence in IAP

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Item 04 (Ref. 2.1.4.10)

T This IFI represents a concern (originally licensee identified) that proper post maintenance Inservice Inspection (ISI) and Testing (IST)

was not always being specified for repairs on ASME Code materials

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and' components.

From a review of the IAP action item files the inspector found

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items had'been completed.

This involved the licensee's issuance of

an Engineering Practice and a Plant Procedure covering specification

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ofl post maintenance' test requirements. :Both procedures (ENP-16.12,

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approved October 4,1989 and PLP-08, approved November 21, 1989)-

were reviewed by the inspector.

In addition, the inspector verified

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records. indicating maintenance planners had been trained in

application of the procedures ISI and IST: requirements.

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'The inspector was unable, however,- to verify that implementation of i

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the above actions had been effective.in correcting the matter of

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concern.

First, centrary to the ~11censee's requirements, there was

.i no manager's report of the ef fectiveness of the-completed actions

"(See 2.a(3) above) in the licensee's IAP item file.'

Although:one i

was provided in response to the inspectors questions, the report did

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not truly provide significant data to support effectiveness.

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In discussions with the NRC inspector,. responsible licensee l

personnel indicated a belief that there had been improvement in-Ll

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specifying correct Inservice Inspection and Testing requirements for

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repairs,.but that further review of data -(from experience -in the

l current refueling outage) would be needed to verify the' actions taken were - effective.

The inspector checked -inservice tests

specified'for seven recent repairs and found all were correct.

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j did not consider this a sufficient sample, however, h

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g In view of the statements by the responsible licensee personnel, the IFI will remain open pending licensee accumulation of evidence to support the effectiveness of their actions and NRC verification of this evidence.

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In examining licensee work requests for proper specification of the

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ISI and IST-requirements the inspector noted that planners did not always correctly mark the work requests as ISI work requests such that they would receive post work reviews by ISI/IST personnel for adequacy.

According to the Supervisor, ISI/IST, such reviews were required and the inspector informed him of the apparent discrepancies.

These discrepancies were observed, for example, on work requests 90-ANSD1, 89-BBFL1 and 90-ABTR1.

This will be examined further in subsequent inspection of this IFI.

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(Closed) IFI 50-325, 324/89-34-29: Followup on results of Site Work Force Control Groups Charter / Guidelines Review in IAP Item 021 (Ref.

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2.1.3.3)

This IFI represents a DET concern that administrative control of the Site Work Force Control Group's -(SWFCG) activities was too informal o-in that their functioning was described only in guidelines that lacked detail.

The SWFCG functions to coordinate schedules of-site'

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work activities-among the various plant organizations.

The DET

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specifically did not find fault with the performance of the.SWFCG, only with the lack of detailed procedural administrative control.

From a review of'the' licensee's files and discussions with the SWFCG Chairman, the inspector determined that the licensee had completed the-Level 1 and 2 action items for this IFI. _The licensee had.

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developed a detailed Site Work Force Guideline (approved June 11,-

1990) which the inspector _ verified _ _ This document appeared to still lack some administrative details such as details of the organization

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and the responsibilities of _ members.

However, the inspector:found

.that the plant General Manager had requested that the guideline would be converted 'into a Brunswick Site 'Procedare which should ensure sufficient, administrative. control.

The General Manager stated that.

this conversion would be considered as a commitment.

The inspector

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is satisfied that the matter is adequately' addressed.

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General Comments on IAP Item Files The inspector informed the licensee that the IAP item files reviewed appeared deficient in several respects:

'(1) There was no index of the documents included in 'an item file and their purposes.

This contributed to difficulties in identifying data to support completion and effectiveness.

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(2)-. Independent Jassessments of item completion (see 2.a(a)) were not identified as such in the files for two of the three IFIs reviewed (89-34-19 and 29).

Further, these assessments were not dated or signed.

-j (3) There was no effectiveness report from management in one of the

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files examined (89-34-21), although there should have been.

l This was not recognized until questioned by the inspector..

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Exit Interview The inspection scope and results were summarized on September 28, 1990, with those persons indicated in paragraph 1.

Dissenting conments were not received from the licensee.

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Acronyms and Initialisms ASME -

American Society-of Mechanical Engineers CQA--

Corporate Quality Assurance Diagnostic Evaluation Team DET

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Integrated Action Plan IAP i

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. Inspector Followup Item

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Inservice: Inspection ISI

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IST Inservice Test

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Nuclear Regulatory Commission NRC

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SWFCG-'

Site Work Force Control Group

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