ML20134M238

Insp Repts 50-324/85-24 & 50-325/85-24 on 850722-26. Violation Noted:Failure to Implement Administrative Instruction (AI)-59, Jumpering,Wire Removal & Designated Jumper

ML20134M238
Person / Time
Site:	Brunswick
Issue date:	08/21/1985
From:	Debs B, Poertner W, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134M222	List: ML20134M218 ML20134M225 ML20134M238
References
50-324-85-24, 50-325-85-24, NUDOCS 8509040033
Download: ML20134M238 (7)

See also: IR 05000324/1985024

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. p Cte UNITED STATES'

_h o NUCLEAR REGULATORY COMMISSION

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g ,j 101 MARIETTA STREET,N.W.

• '* ATLANTA, GEORGI A 30323

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Report Ncs.: 50-325/85-24 and 50-324/85-24

Licensee: Carolina Power and Light Company

P. O. Box 1551

Raleigh, NC 27602

Docket Nos.: 50-323 and 50-324 License Nos.: DPR-71 and DPR-62

Facility Name: Brunswick 1 and 2

Inspection Conducted: July 22-26, 1985

Inspectors: W. 23mL_ Blat lK

W. K. Poertner Date Signed

L).V M d - , mu, _81 Z s l % 7

P. D. Wagner I Da'te ' Signed

Approved by:

B. T. Uebs, Acting Chief

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Da[eSigned

Operational Programs Section

Division of Reactor Safety

SUMMARY

Sccpe: This routine, unannounced inspection involved 80 inspector-hours on site

in the area of maintenance programs.

Results: Within the areas inspected, one apparent violation was identified

(Failure to Implement Administrative Instruction (AI)-59, Jumpering, Wire Removal

and Designated Jumper, paragraph 7).

85090400338%324

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• J. W. Chase, Manager-Operations

• R. M.-Poulk, Senior Regulatory Specialist

• J. O'Sullivan, Manager-Maintenance

• B. E. Hinkley, Manager-Technical Support

• L. E. Jones, Director, Quality Assurance / Quality Control (QA/QC)

• M. Allen, Regulatory Compliance

C. Parker, Senior Specialist

K. Brennick, Senior Specialist

D. Turner, Planner

Other licensee employees contacted included engineers, technicians,

operators, and office personnel.

NRC Resident Inspector

• L. Garner

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on July 26, 1985, with

those persons indicated in paragraph 1 above. The licensee did not identify

as proprietary any of the materials provided to or reviewed by the

inspectors during this inspection. The inspector described the areas

inspected and discussed in detail the inspection findings. No dissenting

comments were received from the licensee.

3. Licensee Action on Previous Enforcement Matters

(Closed) Deviation 324/85-01-02, 325/85-01-02: Failure of a Senior Reactor

Operator (SRO) Candidate to Satisfactorily Complete All Required Training

Prio. to Taking the NRC SRO Examination.

The response by the licensee dated May 3, 1985, and implementation is

considered acceptable by Region II. Training Instruction (TI)-202,

Replacement Training for Senior Licensed Operating Personnel, has been

revised to provide more definite and comprehensive guidance on the require-

ment for successful completion of the SRO program. The inspector reviewed

the revision to TI-202 and found it acceptable,

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(Closed) URI 324/85-01-04, 325/85-01-04: Failure to Conduct a Walk-through

of Control Room Inaccessibility.

The inspector verified that a walk-through of control room inaccessibility

was conducted during the first quarter of 1985 as committed to in Inspection

Report 325, 324/85-01,

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Inspector followup Items

(0 pen) IFI 82-26-02: Response to QA/QC Audit Findings of Training Program.

The licensee has not completed actions to close this item.

6. Preventive Maintenance and Predictive Maintenance Programs

The inspectors conducted a review of the licensee's implemented preventive

maintenance program (PM). This review consisted of reviewing the licensee's

administrative, quality, and maintenance department procedures, and

interviewing selected individuals who were responsible for planning,

scheduling, tracking, developing and working PMs.

Brunswick's preventive maintenance program is defined in Maintenance

Procedure (MP)-10, Preventive Maintenance Program. This program uses a

computer based system to schedule regular periodic preventive maintenance

and document performance and review of these activities.

Activities which are not accomplished are reported and the activity will

then be rescheduled or cancelled with the reason for nonaccomplishment

documented on a PM exception form. Activities that are not accomplished are

reported as overdue. A review of overdue preventive maintenance activities

for safety-related, Technical Specification and other surveillance related

equipment reflected that overdue activities were not excessive and were not

extensively overdue.

As part of the Maintenance Improvement Program, efforts are currently

underway to convert the existing PM program to a " systems" based program

whereby PMs will be conducted concurrently by all maintenance disciplines

when a system is placed under clearance. By scheduling preventive

maintenance in this manner, system availability will be maximized,

particularly for those systems important to safety.

Brunswick has implemented a pilot predictive maintenance program for

selected components such as the reactor feed pumps, recirculation motor-

generator sets, nuclear service water pumps, and the main turbine generator.

This program is conducted on a regular basis and provides for analysis of

vibration, current, discharge pressure and run time. Also, the emergency

diesel generators are operated monthly for a minimum of two hours. During

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this two-hour period,. temperature and pressure data is collected and

forwi;rded to the maintenance staff. The staff then graphs and trends the

data. The overall goal of the predictive maintenance program is to reduce

premature equipment failure and minimize unscheduled downtime.

7. Mechanical, Electrical and I&C Maintenance

References: (a) Maintenance Procedure (MP)-04, General Maintenance

Procedure

(b) MP-10, Preventive Maintenance Program

(c) MP-12, General Cleanliness Procedure '

(d) MP-14, Correcti_ve Maintenance

(e) MP-25, Qualification of Weld Procedure Specifications

and Welders-

( f.) Mi-48, Pilot Predictive Maintenance Program

(g) MP-30, General Welding Procedure

(h) Administrative Instruction (AI)-02, Feedback of

Operating Experience

(i) AI-17, Plant Housekeeping

(j) AI-21, Non Tech Spec Surveillance Test and Preventive

Maintenance ,

(k) AI-58, Equipment Clearance Procedure

(1) AI-59, Jumpering, Wire Removal . and Designated Junper

(m)' Fire Protection Procedure (FP)-02, Control, of

Combustible Materials and Ignition Sources 4

(n) FP-05, Welding and Burning Control

(o) Plant Performance Procedure' (PPP)-14, Plant- Performance

Data Analysis -

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(p) PPP-15, Planti Performance Trending and Analysis ',

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Operating Instruction-(0I)-23, Trending Analysis

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(r) Engineering- Procedure (ENP)-16, Procedure 'for-

Administrative Control of Inservice Inspection 't

Activities.

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(s) ENP-3, Plant Modification Procedure

(t) Training Instruction (TI)-303, Clearance Training

The inspectors reviewed the references and other implementing procedures and

conducted interviews with plant management, operations and maintenance

personnel to verify that the licensee's maintenance program contains the

following attributes.

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Written procedures were established for initiating requetts for routine

and emergency maintenance.

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Criteria and responsibilities for development, review and approval of

maintenance requests were established.

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Criteria and responsibilities that form the basis for designating the

activity as safety or non-safety-related were established.

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Criteria and responsibilities were designated for performing work

inspection of maintenance activities.

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Administrative controls for special processes were established.

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Methods and responsibilities for equipment control were clearly defined

and established.

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Written procedures were established and responsibilities designated for

cleanliness control of safety-related components and systems.

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Administrative controls and responsibilities for general housekeeping

were established.

Brunswick is presently implementing a Maintenance Improvement Program. This

program was developed to promote improved maintenance activities and to

address perceived performance weaknesses. The program is structured to

reflect regulatory requirements, improved efficiency in the use of

resources, and the establisnment of performance standards based upon

excellence. The Maintenance Improvement Program delineates five objectives

and specifies the action items required to be completed in order to achieve

these objectives. Responsible individuals are assigned along with

completion due dates. The objectives range from reviewing the maintenance

organizational structure to establishing and maintaining a work environment

which contributes to good employee morale. The Maintenance Improvement

Program is presently scheduled for completion early in 1986.

The inspectors observed the process by which the maintenance planners

prepare trouble tickets once they are received. It was noted that the

planners were very thorough to insure that the appropriate procedures and

retest requirements were specified. Once the work is planned, a computer

based tracking system called the Work Order Tracking Systems (WOTS) is used

to track the status of the trouble tickets. Based on interviews with

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licensee personnel, information is sometimes difficult to retrieve from the

WOTS due to inconsistencies in entering information into the system. A

major drawback to the WOTS is that it only contains a short abstract from a 4

trouble ticket and, therefore, may not be an accurate account of the scope of

the job. Since the information contained in the WOTS may be sketchy or

inaccurate, it is of limited usefulness in looking for trend information. ,

The majority of safety-related trending analysis is performed through the

Nuclear Plant Reliability Data System (NPRDS). The planners do flag trouble

tickets with the words " repetitive failure" if they are able to determine a

similar failure from equipment history files. The licensee is planning to

implement an Automated Maintenance Management System ( AMMS) as part of the

Maintenance Improvement Program. This new system will provide complete and

accurate trouble ticket information which will improve both tracking and

trending of work. The AMMS will also improve the maintenance history

retrieval process.

The inspectors reviewed numerous safety-related work packages to determine

compliance with MP-14, Corrective Maintenance. No discrepancies were noted

in the work packages reviewed. The inspectors determined that the plant

presently has approximately 7500 outstanding trouble tickets. It is

intended that the Automated Maintenance Tracking System will be able to help

reduce the amount of outstanding trouble tickets.

While reviewing the clearance index and the jumper and wire removal log, the

inspectors discovered that the electrical leads to the local SIREN on all

four Diesel Generators had been lifted to prevent excessive currents through

the alarm circuitry. The wires were tagged in the clearance log as being

lifted but were not identified in the jumper and lifted wire removal log.

Further investigation determined that wire removal tags for corrective

maintenance are not required to be entered in the jumper and wire removal

log as long as they are documented on the trouble ticket. However, the

diesel generators were returned to service and declared operable with these

electrical leads lifted. This item was turned over to the resident

inspectors for further investigation. AI-59 requires the Operations

Engineer to report to the Plant Nuclear Safety Committee (PNSC) monthly on

the status of both safety and non-safety-related jumpers and wire removals.

AI-59 also requires the Manager-Maintenance and the Manager-Technical

Support to report to the PNSC monthly on the status of trouble tickets and

Engineering Work Requests required to remove jumpers or reterminate wire

removals. Presently, the Operations Engineer only reports jumpers and wire

removals listed in the jumper and wire removal log and the Manager-

Maintenance and Manager-Technical Support de not report the status of

trouble tickets or Engineering Work Regr si ~ This failure to implement

AI-59 is identified as a violation (329 '20 * 5-24-01).

The inspectors noted several other inst.. 3s were work was not being

accomplished exactly as prescribed in approved : procedures. AI-17,

Housekeeping, requires that cleanliness inspections be conducted and any

discrepancies documented on Attachment 3 of AI-17. Cleanliness inspections

are conducted and documented; however, discrepancies are not documented on

Attachment 3 as required by AI-17. AI-58, step 4.1.2.3(1) requires that the

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clearance approval signature will not be granted until the restored position

on the clearance tag sheet is filled in. The inspectors noted several

instances in the active clearances where this had not been accomplished.

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Review of the completed clearance log showed no instances were the restored

position block had not been filled in. These two items will be identified as

an inspector followup item (325, 324/85-24-02).

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