ML20134M238
| 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: |
| References | |
| 50-324-85-24, 50-325-85-24, NUDOCS 8509040033 | |
| Download: ML20134M238 (7) | |
See also: IR 05000324/1985024
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET,N.W.
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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.:
Facility Name: Brunswick 1 and 2
Inspection Conducted: July 22-26, 1985
Inspectors: W. 23mL_
Blat lK
W. K. Poertner
Date Signed
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P. D. Wagner
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Da'te ' Signed
Approved by:
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B. T. Uebs, Acting Chief
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).
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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
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(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
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(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
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(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 ',
-(q) Operating Instruction-(0I)-23, Trending Analysis
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(r) Engineering- Procedure
(ENP)-16,
Procedure
'for-
Administrative
Control
of
Inservice
Inspection
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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.
Criteria and responsibilities were designated for performing work
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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
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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.
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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
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instances in the active clearances where this had not been accomplished.
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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