ML20115C128
| ML20115C128 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/12/1992 |
| From: | Jonathan Brown CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BSEP-92-028, BSEP-92-28, NUDOCS 9210190170 | |
| Download: ML20115C128 (3) | |
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Cpga Carolina Power & Light Oompany mfMMMM Brunswick Huclear Project P. O. Box 10420 Southport, N.C.-
28461-0429 October 12, 1992 FILE:
B09-13510C 10CFR2.201 SERIAL:
BSEP-92-028 U.S. Nuclear Regulator) Commission ATTN Document Control Desk Washington, D. C.
20555 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND SPR-62 SUPPLEMENTAL REPLY TO A NOTICE OF VIOLATION Genhement Tus aswick Steam Electric Plant (BSEP) received NRC Inspection Report.
5 0 - 3 '.
92-21 and 50-324/92-21 and found that it did not contain information of a proprietary nature. The report included a Notice Of Violation.
Carolina Power & Light Company (CP&L) responsed to.tha Notice of Violation on September 21, 1992 (Serial:
As documented in that response and discussed in a September 21, 1992, telephone conversation between Mr. H. O.
Christensen - Chief Project Section 1A, Reactor Projects Branch No. 1, Division of Reactor Projects, and Mr. S. D. Floyd - BSEP Manager Regulatory Compliance, the response to Violation A, example 2 was to be
_l supplemented by October 12, 1992.
Enclosed is Carolina Power & Light Company's supplemental response.
Very truly yours, D
J. M. Brown, Plant Manager Unit 2 Brunswick Nuclear Project TMJ/
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10 0 U hv, Enclosure cca Mr. S. D. Ebneter Mr. R. H. Lo BSEP NRC Resident Office 4
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s ENCLOSURE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION VIOLATION At Technical Specification 6.8.3 a retiuires that written proceduras shall be A.
established, implemented and malntwined covering the activities recommended in Appendix "A"
of Regu2 atory Guide 1.33, Nove,.nber 1972 including procedures for performing mair.*.enance.
1.
Maintenance Procedure, MP-12, General Citaaliness Procedure, Revision 13, Section 5.4.2.3 requires that openings in hardware and piping sha)). he e=pped, covered, or plunced when not in use.
Contrary to the aMve, MP-12 was not properly implemented in that on July 10,1992 the 2C conventional' service water pump discharge check valve (2-SW-V!3) was used as a work surface with the valve internals exposed resulting in maintenance decris being introduced to the internals.
2.
Maintenance Management Manual OMMM-004, Preventive. Maintenance, Revision 5,
Section 5.1.3.14 requires that any. deviations from manufacturer's recommendation should be handled in accordance with-ENP-20.
Section 5.0 states that a Preventative Maintenance (PM) exception form should be submitted as soon as it is determined a PM will not be performed.
Enginearing Procedure, ENP 20, Engineering Work Request (EWR), Revision 14c, Section 10, states that if action not taken deviates from the vendor's recommendation, a deviation form should be attached to the ENR package. This package requires two levels of engineering supervisory approval, Nuclear Assessment Department (NAD) review and Plant General Manager approval'.
Contrary to the above, ar of July 31, 1992, the' licensee failed to obtain the two level enginaering. supervisory. approval,. the NAD review and Plant General Manager approval for ; deferring the preventive maintenance since 1983 on two. safety-related 4160 volt circuit breakers.
This is a Severity Level IV viciation (Supplement I).
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4 SUPPLEMEN s'AL RESPONSE TO VIOLATION A - EXAM &E_2 l
Admission or Denial of Violations j
CP&L admits that the Preventive Maintenance (PM) program is in need of f
imprcvements.
As stated,-the example is not entirely accurate; however, CP&L agrees that the process for controlling deferral of preventive maintenance is less than adequate and accepts the violation.
Clarification of the Violation f
The 4160 volt circuit breakers deferred from preventive maintenance since 1983 are not safety related and the ENP-20 process for approving deferral of PMs was not required.
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Maintenance Management Manual, OMMM-004, Preventive Naintenance, revision 5,
section 5.1.3.14 is not applicable to existing PM routes. Section 5.1 of OMMM-i 004 is entitled " General Information".
Sub-section 5.1.3 establishes the criteria Maintenance personnel are to consider when establishing a schedule for new PM routes.
5.1.3.14 is the fourteenth criterion in sub-section 5.1.3.
5.1.3.14 requires that when schedules being established for new PMs deviate from that recommended by the manufacturer, che deviation should be handled in I
accordance with ENP-20.
It does not require that deferrals of existing PMs be handled in accordance with ENP-20.
Deferrals of existing PMs are handled in accordance with section 5.9 of OMMM-004, entitled " Preventive Maintenance Exceptions".
Section 5.9 does not refer back to ENP-20; therefore, the ENP-20 approvals were not required.
a Reason for the Violation:
Prior to the issuance of this violation, several sources internal to CP&L had identified concerns with the administration of the PM Program.
As a result, 4
adverse condition reports (ACRs) were initiated in accordance with the Corrective i
Action Program (CAP) and a root cause analysis (RCA) was initiated.
1 The RCA documents that the PM Program has existed since 1976 and has experienced various efforts to assess and enhance it.
In 1982 approximately 110 new PM Procedures were developed which provided for in excess of 851 individual tasks.
subsequently, the PM Program has grown to approximately 20,000 individual tasks.
However, an effective process was not in. place to document the basis or coordinate the performance of the PMs. The result has been an inef ficient, labor-intensive, PH program which is difficult to assess or revise.
Corrective Steos Which Have Been Taken and Results Achieved As an interim measure, by management directive, PM exceptions are being reviewed by Technical Support personnel. When a concern exists with the exception an EWR l
1e initiated in accordance with appropriate engineering procedures.
Corrective Steos Which Will Be Taken to Avoid Further Violations A three year improvement plan for the Brunswick Nuclear Project is being developed. The corrective steps which will be taken to improve the PM Program will be included in the plan when it is transmitted to the NRO.
Date When Full Comoliance Will Be Achieved:
CP&L is currently in full compliance.
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