ML20005D744

Responds to Violation Noted in Insp Repts 50-313/89-30 & 50-368/89-30.Corrective Actions:Efforts Clarifying & Strengthening Relationship Between Engineering & Maint Initiated

ML20005D744
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/05/1989
From:	Ewing E ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN128902, CAN128902, NUDOCS 8912140410
Download: ML20005D744 (3)

Text

.

.m.- -

s

)' Arkinoas P:wer & Light Company :

e .. - / 425 West captol

e' " " " ' ~

P. O Box 551 Little nock, AR 72203 h Tel 501377 4000 p

December 5,t1989 1

. SCAN 128902 U.'S. Nuclear Regulatory Commission

' Document Control Desk Mail Station P1-137 Washington, D. C.-20555

SUBJECT:

Arkansas-Nuclear One - Units 1 and 2-Docket Nos. 50-313/50-368 'l License Nos. DPR-51 and NPF-6 i Response to Inspection Report 50-313/89-30; 50-368/89-30 .j l

Dear Gentlemen:

In the subject inspection report, Arkansas Power & Light was requested to i review the maintenance and engineering personnel involvement when discre- j pancies are identified during the conduct of maintenance. As discussed in '

the cover letter of our response to -Violation 313/8930-01, dated October 6, i 1989 (0CAN198903), this letter provides the results of our review in the enclosed attachment.

Very truly yours,

, E. . Ewing

General Manager Technical Support and Assessment L ECE/JDJ/1s1 L' -Attachment I- . cc

Regional Administrator Region IV L'o U. S. Nuclear Regulatory Commission  ;

I 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011  ;

1 l

[ pol '

1 l t

l t l l

i ,,

.'8912140410'091205 E' ' 'PDR ADOCK 05000313

, ..A GD0 - J

'? ' t 'U.'.S. NRC

- Attachment' Page 1-December,5, 1989 REVIEW 0F MAINTENANCE INTERFACE WITH ENGINEERING

' Based'on observations by AP&L management, the lack of engineering involve-ment is attributed to the informality of (1) engineering and maintenance L interface concerning engineering involvement and (2) documenting L engineering resolution when involved. These informa11 ties result'in E failure of maintenance personnel to stop work and ensure'that proper engineering support and approval is obtained and failure to properly document engineering resolutions prior to commencing work activities (e.g.,

in some cases, resolution was obtained informally by telephone and not followed up with written evaluations).

Efforts have been initiated which have clarified and strengthened the rela-tionship between maintenance and engineering. When the incident was identified in Inspection Report 50-313/89-28; 50-368/89-28, a memorandum was issued to all maintenance personnel (ANO-89-07321, dated August 11.,1989) which emphasized the responsibilities of maintenance personnel with regard to configuration control. Directions were given to stop work and contact a maintenance engineer whenever a condition was encountered during work which potentially impacted the design of the plant. The maintenance engineer is to evaluate the condition and determine if a change to the configuration of the plant is involved. The evaluation performed by the maintenance engineer is to be documented in writing and maintained as part of the job order package. Training on the requirements of this memorandum was included in training conducted for the maintenance staff on November 21 and 22, 1989, and in subsequently scheduled makeup sessions.

A maintenance engineering administrative procedure has been issued which ,

contains the responsibilities of the maintenance engineers, including those outlined in the memorandum discussed above. These duties include supporting the planning of maintenance work activities, as necessary, by performing technical evaluations of problems identified in job requests or by providing a technical basis for Work instructions in a job order. This will help  :

identify potential configuration concerns before the work is started. At any point in the maintenance process, a maintenance engineering technical evaluation may be used to determine if a problem involves a change to plant design. If so, then a Plant Engineering Action Request (PEAR) is initiated to evaluate and implement the design change. Technical evaluations related to job orders become part of the job order package and serve to document engineering resolutions.

The maintenance engineering staff will continue to provide the liaison between the maintenance group and the engineering groups responsible for configuration control. Maintenance personnel are aware that the maintenance engineers are available to perform this function, and the maintenance engineering staff is being increased to better support the needs of the maintenance group.

Specific action assignments are being made through the Condition Reporting (CR) system to formally involve engineering in determining appropriate corrective actions when conditions are identified by maintenance which require engineering resolutions.

,pe'*~ y a, e .. *c U. S; NRC -

• ', Attachment Page 2 December,5, 1989 Changes;to appropriate procedures have'been initiated to clearly delineate the role of _ maintenance engineering in supporting maintenance activities i and the responsibilities of maintenance personnel to stop work and use the i maintenance engineering staff to resolve potential configuration concerns.

These revisions will be completed by January 15, 1990.

AP&L is currently reviewing the Diagnostic Evaluation Team (DET) issues related to this subject. Any further actions related to this issue will be addressed as part of our response to the final DET report.

More recent observations by AP&L management and supervision indicate a significant increase in engineering involvement with maintenance activities.

The actions that have been taken and are planned (i.e., procedure changes and increase in maintenance engineering staff) to further enhance the maintenance / engineering interface will better control and formalize the process of involving engineering in maintenance activities.

i e

a w --- e -,. r -