ML14079A237
| ML14079A237 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/16/2013 |
| From: | Duke Energy Carolinas |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14079A232 | List: |
| References | |
| BSEP 14-0029, TAC ME9623, TAC ME9624 | |
| Download: ML14079A237 (10) | |
Text
Enclosure 5 Fourth Quarter 2011 Fire Protection Program Health Report
Tuesday, July 16, 2013 PROGRAM IQ Program Health Report Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 1 72.63 v Prouram Health Report (1 101- 12131/2011'I Piant Fleet Program Pliager Rouns, Timothy Overal Statu Fadiy Brunswick FackumpProg uMmgl Becker, John Porm FP 72.63 Y
PH c"Oupt.smeb Complete motorau Complete Progrim Due Fire Protection / Nuclear Safety Capability Assessment Historic Fuem The current health of the BNP Fire Protection Program for BNP is YELLOW for end of 4th Q 2012.
The trend is declining.
Additional management attention is warranted at this time due to the staffing challenges in both FP and SSA/ SBO.
Monthly site leadership updates of program health was secured in 2011, with the intent to rely on the plant health committee review process.
- 1. Red/ Yellow indicators:
- a. Self identified and external findings: During the quarter the NRC tri-enniel inspection occurred. This inspection had the positive result of no NRC findings or open issues. The inspection process did initiate a number of S3 NCRs to address minor issues identified during the inspection process. Separate from the NRC inspection process, S2 NCRs related to our own inspection activities were identified. These included cable raceway separation issues noted as not compliant with our existing SSA as well as NFPA 805 future requirements. These two issues have been responded to with the implementation of roving fire watches as a compensatory action. This has placed an unplanned burden on supporting departments of operations, and security. Corrective actions are to be dveloped as part of the the NFPA 805 project.
- b. Training and Qualification: Replacements for vacandes are activiely being pursued, but there has been a 10 month gap in the SSA position. This has placed a high reliance on contract personnel for technical expertise. One qualified FPE now works in systems with other assignments than fire protection.
- c. Corrective Action Backlog: Progress has not been made in addressing average age of fire protection actions.
- d. Failure rate of emergency lighting units continues as an equipment issue.
- 2. Backup Program Managers concerns:
- a. Design and Project support of EC development and implementation continues to challenge existing resources. With increased projects planned for 2012 and 2013 this will likely be an increasing burden and a potential distraction from program activities. Additional contract FP engineering expertise has been aligned to assist in this workload as well as addtional positions in corporate roles.
- b. The data collection process for the performance indicators needs to be validated for BNP 4th quarter.
- 3. Summary of proactive actions schedlued to assuer longterm program health:
- a. The project to clean out the transformer pits and convert to an open pit design has been developed and a project manager assigned. This will provide a resolution to a longstanding degraded condition.
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Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 1 72.63 Y Value Weight Score Contribution Self-Identified and External Findings No Significance Level I NCRs AND Y 12.50 50 6.25 any of the following: 1 Significance Level 2 NCR OR > 4 Significance Level 3 NCRs OR I external finding.
Regulatory/Industry Forecast One recent / pending NRC or w 12.50 75 9.38 industry issues which require significant (> 100 MH) effort to invpctin2mt 2 mritinn I rnndeitnn Program Human Performance 12.50 100 12.50 Training and Qualification 6.50 0 0 Self Assessment 6.50 100 6.50 Benchmarking 6.50 100 6.50 Operating Experience 6.50 100 6.50 Open Corrective Action Program Items 6.50 0 0 Frequency of LOCT on Safe Shutdown procedures 5 100 5 SSD Equipment impairments from periodic/surveillance testing 5 0 0 Fire Events 5 100 5 Property Loss Control Performance Indicator 5 100 5 Fire Protection Equipment Reliability per NEIL reporting criteria. 5 100 5 Fire Protection Power Block related Corrective Maintenance Backlog 5 100 5 Total Score: 72.63 Y Expected Green: Not Set Expected White: Not Set 7/16/2013 2/9
Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 1 72.63 yl Indicators Self-Identified and External Findings Score: F50 Y 3ustification:
4th quarter NCR data needs to be developed/verified.
There were the following 3 S2 NCRs in the 4th quarter:
499666 cable not identified as APP R 503011 deisel driven fire pump battery charger failure 503132 SSA cable raceway impacts 9 S3 NCRs related to impariments:
491873 492408 494808 494976 499013 499535 502625 503656 504611 Trienniel related NCRs 496983, LABELS READING "HOT' ON 120 VAC/125 VDC PANELS IN 4KV E-BUS 496998, DRAWING 1-FP-81283 ERRONEOUS INFORMATION 497159, MWT BUILDING ROOF LEAK ABOVE DIESEL FIRE PUMP BATTERIES 497468, PROCEDURE 1ASSD-05 INCORRECTLY LISTS MCC 1XB 497514, AVAILABILITY OF LOCKED HIGH RAD AREA KEYS FOR ERO 497529, DRAWING LL-09234 SHEET 27 SHOULD BE LABELED UNITS 1 AND 2 497553, REVISE THE BCAMS DATA BASE TO CAPTURE EXPOSED CABLING 497681, DETERMINATION OF CREDITED COMMUNICATION METHOD FOR EDMGS 499144, MAINTAINING CONTROL ROOM MIN STAFFING DURING ASSD PROCEDURES 499600, ADDITIONAL CLARIFICATION NEEDED FOR EVAL 85-125-0-27-F 499666, CABLE DW1-L6G/1 NOT IDENTIFIED AS APPENDIX R RELATED 499773, LETTER OF AGREEMENT WITH OFF-SITE SUPPORT AGENCIES (SOUTHPORT FD) 499786, OFF-SITE MOU RENEWAL REQUIREMENTS DONT MATCH IN PROCEDURES 499962, AMPACITY CALCULATION BNP-E-5.036 CONTAINS AN ERROR 499975, COORDINATION CALCULATION BNP-E-8.010 CONTAINS AN ERROR 500079, HOT SHORT OR FAULT MAY POTENTIALLY IMPACT E2 FIRE DAMPER Yellow for 3rd Q 2011 with a total of 14 Severity Level 3 NRC's listed below.
DATE PRIORITY NCR ARSUBJECT 20110715S3 476749 NEIL REPORT FOR FIRE SUPPRESSION SYSTEM OUTAGE 20110811S3 481844 NEIL NOTIFICATION FROM IMP 2013 DG FIRE PUMP INOP 20110817S3 482978 FIRE BRIGADE RADIOS NOT WORKING DURING FIRE DRILL 20110906S3 486464 SA #440002, D1, CONFIGURATION CONTROL - NFPA CODE COMP CALCS 20110907S3 486586 SA #440002, D3, INSUFFICIENT SITE PRIOR. ON FP PROG. MAINT.
20110907S3 486587 SA #440002, D4, PROCEDURAL NON-COMPLIANCE 20110907S3 486588 SA #440002, D5, FIRE BRIGADE TRAINING 20110912S3 487388 BNP - FIRE EXTINGUISHERS MISSED MONTHLY INSPECTION 20110915S3 488058 7 DAY FIRE BARRIER PENETRATION IMPAIRMENT EXPIRING 20110915S3 488059 7 DAY FIRE BARRIER PENETRATION IMPAIRMENT EXPIRING 20110915S3 488062 7 DAY FIRE BARRIER PENETRATION IMPAIRMENT EXPIRING 20110915S3 488068 7 DAY FIRE BARRIER PENETRATION IMPAIRMENT EXPIRING 20110925 S3 489976 7 DAY FIRE IMPAIRMENT WILL BE EXCEEDED 20110929S3 491157 SCAFFOLD POTENTIALLY BLOCKS FIRE FIGHTING ACCESS TO RB2 SRHR 5 NRCs written for planned expired impairments due to implementation of ECs. All were associated with EC 50934 to install new fire detection and deluge valves for the Four Day Fuel Tank Rooms. 2 NCRs written for NEIL notification of suppression systems out of service for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Harris applies a different standard and does not write MCRs for planned expired impairment and NEIL notifications. NCR 495257 written to address.
3/9 7/16/2013 7/16/2013 3/9
Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 I 72.6i___,]
Indicator: COMPLIANCE Score: [75,I lustfication:
New Self-Identified & External Findings criterion is implemented for the 2011 program health report. Using the criteria, this indicator was green for the 1Q 2011. Experience in 2011 to date found Significance Level 3 NCRs will keep this indicator YELLOW. Low level events in areas planned expired impairments and NEIL notifications for suppression systems out of service for maintenance have caused 50% of the S3 NCRs. Less than two S3 NCRs are needed to have a white indicator. OE found BNP writes NCRs for NEIL notification and planned expired impairments while other sites do not.
Remaining COMPLIANCE indicators are green and no change is expected for the remainder of 2011.
Indicator: Regulatory/Industry Forecast Score: 75 W Jusi~ficationa NFPA 805, Indicatorn Program Human Performance Score:
Justiflcation:
Criteria met for4th Q 2011 year.
Indicator: Training and Qualification Score:
Position became vacant in Jan 2012 due to promotion. Backup not qualilfied.
Indicator: Self Assessment Score:
Green for 4th Q 2011 FP Program Self assessment SA # 440002 completed in September 2011.
NOS Assessment of the Fire Protection Program debriefed in July 2010.
EFFECTIVENESS Score: 160 II Currently, two aged corrective actions are open causing an indicator to remain RED.
These corrective actions require greater than 40 man-hours under level of effort to complete. This level of effort is not built into the program manager's work load resulting in several extensions.
Remaining EFFECTIVENESS indicators are green and no change is expected for 2011.
Benchmarking Score:
lmusficatina Criteria met for 4th Q 2011.
Benchmarking activity used to prepare for the 2011 NRC Fire Protection Triennial Inspection. Experience from HNP Triennial used during preparation, pre-job brief and post job critique for the NRC information gathering trip in October 2011. NRC Question database adopted for use at BNP as a result. PM supporting INPO FP assessment of Calvert Cliffs in December 2011 7/16/2013 4/9
]
Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 1 72.63 yi Indicator: Operating Experience Score:
3u~dfcation:
Criteria met thru 4th Q 2011.
OE from HNP Triennial used during preparation, pre-job brief and post job critique for the NRC information gathering trip in October 2011. NRC Question database adopted for use at BNP as a result.
No open OE found for Fire Protection Program Open Corrective Action Program Items Score:
usfcation:
Scored red due to continued lack of progress in reducing age of CAP backlog. This criteria needs needs revision by the fleet program team to meet current CAP timeliness expectations. For example, white or SAT should be less than 180 days average age for CORR.
Open Corrective Actions exceeding criteria at end of 3nd Q 2011 include; NCR 358391-20 UPDATE DRAWINGS DEPICTING SPRINKLER SPRAY SHIELDS extended 4 times.
NCR 382623-05 PREPARE CALC FOR ALLOWABLE LIMIT OF UN-COATED CABLES IN CABLE SPREAD ROOM extended 5 times Other open CORRs with extensions indude (not counted against criteria)
NCR 413438-06 UPDATE SUBTYPE FPC CALCULATIONS <1 year & 1 extension NCR 411611-16 UPDATE OVERDUE SUBTYPE FPC CALCULATIONS <1 year & 2 extensions No CAPRs open.
PERFORMANCE Score: F83.33- -]
Data not updated for 4th quarter.
The Property Loss Control Performance Indicator returned to GREEN in March 2011.
An area of concern is the Fire Events category. BNP had three fires in February and March 2010. During the 2011 Unit 2 refuel outage, hot work controls were dosely observed by Operations and NOS. No fire events occurred during the B220R1 outage.
Remaining PERFORMANCE indicators are green and no change is expected for 2011.
Indicator: Frequency of LOCT on Safe Shutdown procedures Score:
3ustficatinr Met for 3nd Q 2011.
Review of LOCT schedule found ASSD Review and Walkdowns presented during cycle 2010-5.
Station Blackout & AOP-36.2 training given during cyde 2011-3.
Indicator: SSD Equipment impairments from periodic/surveillance testing Score:
Jusifications A total of five (5) impairments on ASSD equipment found in 2011 due to surveillance testing.
Review of OTS found four impairments on ASSD equipment due to failed surveillance test in 3nd Q 2011.
7/13/11 2-EDCL-2D360 failed MST-ELU11SA.
7/13/11 1-EDCL-1D44 failed OMST-ELU11SA 7/14/11 1-EDCL-1D22 failed OMST-ELU11SA 8/14/11 2-SPP-JAC-JF9 failed OPT-48.4, ASSD Sound Powered Phone System Functional Test.
Maintenance rule allows a 10% failure rate for ELUs. NCR 495261 written to address disconnect between this indicator and MR criteria for ELUs.
Review of OTS found one impairment on ASSD equipment due to failed surveillance test in 2nd Q 2011.
6/28/2011 2-2XDB-B35 - During OMST-RCIC42R Normal/Local Switch unable to insert key T112 into the RCIC Barometric Condenser Vacuum Pump.
7/16/2013 5/9
Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 1 72.63 Y Indicator: Fire Events Score: 100 C, Justificatlnrn No fire events in 2011 thru October 2011.
Three fire events during the 2010 calender year.
NCR 373793 - January 2010 NCR 385082 - March 2010 NCR 389641 - March 2010 No fire events in 2008 and 2009.
Value = 0.5 = Number of fires (rolling three year average) / year / unit Indicator; Property Loss Control Performance Indicator Score:
NEIL Property Indicator is 1.30 (GREEN) as calculated after the 3/16/2011 inspection. This indicator improved from WHITE after the November 2011 inspection.
No change for 3nd Q 2011.
Next inspection in November 2011 and new score will be issued at that time.
Indicator: Fire Protection Equipment Reliability per NEIL reporting criteria. Score:
Met for 3nd Q 2011. Review of NEIL Event Reporting Web application found 5 system impairments entered from July 1st, 2011 thru September 30st, 2011.
Average is 0.833 per month per unit.
Indicator: Fire Protection Power Block related Corrective Maintenance Backlog Score:
7-11-1 Three (3) corrective maintenance work orders found in active status in Passport search on 10/12/2011 for fire protection systems.
Criteria met for 3nd Q 2011.
6/9 7/11,12013 7/16/2013 6/9
Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Perid: Q4-2011 1 72.63 Y1 Indicator Comments COMPLIANCE Self-Identified and External Findinas Rouns, Timothy (10/13/2011 8:56:53 PM) - Run filter under Action Tracking / Action Requests / Action Requests Attributes in Passport Reporting for details.
EFFECTIVENESS Onen Corrective Action Proaram Items Rouns, Timothy (7/21/2011 10:22.35 PM) - NCR 411611-16 REVIEW AND REVISE NFPA CODE COMPLIANCE CALCULATIONS will not be included. This corrective action is dependent on progress of the NFPA 805 transition project.
Rouns, Timothy (10/13/2011 8:58:54 PM) - Run filter under Action Tracking / Assignment and Subs/Action Request Assignment with Attributes in Passport Reporting for count.
Rouns, Timothy (5/4/2011 5:02:19 PM) - Open corrective actions for routine NEIL notifications and NFPA 805 Transition Project are not included.
Benchmarkira Rouns, Timothy (7/26/2011 6:11:14 PM) - OE from Perry event was used during 2nd Q 2010 as an action incorporated from benchmarking. Need to incorporate new benchmarking action in 2011 to keep indicator green.
PERFORMANCE Freouencv of LOCI on Safe Shutdown procedures Rouns, Timothy (7/26/2011 6:49:36 PM) - This indicator is redundant to the same indicator in the Appendix R Health Report.
SSD Eauioment Impalrments from nerlodic/suvelllance testina Rouns, Timothy (7/26/2011 6:49:20 PM) - This indicator is redundant to the same indicator in the Appendix R Health Report.
Rouns, Timothy (10/13/2011 8:59:41 PM) - OS database will be used for ASSD equipment impairment search beginning 2nd Q 2011. Since the LCOS database has been retired, equipment out of service cannot be easily searched prior to 2011. The rolling 12 month average will begin with the second quarter 2011.
Rouns, Timothy (1/31/2011 5:57:52 PM) - Criteria Guidance; Fire Events = Number events/year/unit on a 3 year rolling average in power production areas of the nuclear plant.
Fire Protection Eaulment Reliability per NEIL renortina criteria.
Rouns, Timothy (7/2612011 6:56:41 PM) - NEIL reporting for suppression equipment taken out of service for modification will not be count in this indicator.
An example is EC 50933 Deluge Valve upgrade and control replacement.
Fire Protection Power Block related Corrective Maintenance Backlog Rouns, Timothy (10/13/2011 9:38:09 PM) - Use filter under Work Management / General / Active Work Order Tasks - Simple in Passport Reporter for count.
/0/2ir/ 3ui 7/9
Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 1 72.6 No Records Returned 7/16/2013 8/9
I I Program: PGN I Brunswick I FP - Fire Protection / Nuclear Safety Capability Assessment Period: Q4-2011 72.63 Y1 Fleet Summary Executive Summary Alan Holder is the Fleet Program Manager.
Overall Fleet Health of the Fire Protection Program is YELLOW (Administratively set).
As reported, BNP is WHITE, CR3 is YELLOW, HNP is YELLOW and RNP is GREEN.
The Trend in the Fleet Program Health is STEADY over the past 2 quarters.
Additional management attention IS warranted at this time.
- 1. Discussion of non-green indicators common to multiple sites:
Commonalities in KPI's, other than GREEN, focus inthe areas of;
- 1) Self-Identified and External Findings
- 2) Self-Assessment
- 3) Open Corrective Action Program Items
- 4) SSD Equipment Impairments Some cross counting may be present within these categories and between Program and System Health Reporting. Identification of significance and external deficiencies, along with duration of resolution, present challenges to the resource capabilities assigned at each site.
- 2. Program Managers' Concerns:
2 of 4 sites failed to report Program Health status for 2011 Q4. CR-513462 was generated noting same.
Continued concern is focused on acquisition, training and retention of qualified resources for the FP and SSA Program Manager functional area. Currently, 2 of 8 primary PM positions are vacant and a 3rd expected to be vacated based on personnel re-assignment.
- 3. Summary of proactive actions scheduled to assure long-term health:
During January 2012 face-to-face meetings for both FP and SSA Program Managers refinement of the Program Health Reporting KPIs and weighting were undertaken. Implementation of the refined metrics will begin with the 2012 Q1 reporting. This is expected to better align the metrics with current expected performance, provide a single reporting structure and provide separation in Program and System Health Reporting data.
Brunswick Crystal River Harris Robinson Self-Identified and External Findings Regulatory/Industry Forecast w W w Program Human Performance
- y Training and Qualification Self Assessment w Benchmarking w Operating Experience Open Corrective Action Program Items Y Frequency of LOCT on Safe Shutdown procedures SSD Equipment impairments from periodic/surveillance testing Fire Events Property Loss Control Performance Indicator Fire Protection Equipment Reliability per NEIL reporting criteria.
Fire Protection Power Block related Corrective Maintenance Backlog 16 Y Total:j 72.63 y 1 72.88 y 7/16/2013 9/9